Title
Bambalan y Prado vs. Maramba
Case
G.R. No. 27710
Decision Date
Jan 30, 1928
A minor plaintiff, heir to land, contested a sale under duress; court voided the transfer due to his minority and lack of registration, denying unproven damages.
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Case Digest (G.R. No. 27710)

Facts:

    Background of the Parties and Property

    • The plaintiff, Isidro Bambalan y Prado, is the sole and universal heir of the deceased Isidro Bambalan y Calcotura, who owned the land with Torrens title.
    • The defendants, German Maramba and Genoveva Muerong, challenge the validity of the alleged sale of the land.

    The Alleged Sale Transaction

    • The defendants assert that they acquired the land from the plaintiff by means of a sale executed through a document (Exhibit 1) dated July 17, 1922.
    • The plaintiff admits to having signed the document; however, he claims that his signature was obtained under duress.
- He alleges that Genoveva Muerong intimidated his mother, Paula Prado, by threatening her with imprisonment, which indirectly coerced his assent.

    Financial Considerations and the Loan Transaction

    • In 1915, Paula Prado and her second husband, Vicente Lagera, received a loan from Genoveva Muerong.
- The loan amount is documented as P200 (according to Exhibit 3) or P150 (as testified by Paula Prado).

    Testimonies and Claims for Damages

    • The plaintiff claimed damages in relation to the alleged sale, emphasizing that he was induced by circumstances outside his full consent, in part due to his minority.
    • The only testimony supporting the damage claim came from Paula Prado, which was contradicted by Genoveva Muerong, who additionally asserted that she held about half of the land.
    • The record reveals that there is a lack of sufficient evidence to substantiate the damages claimed by the plaintiff.

Issue:

    Validity of the Sales Contract

    • Whether the document (Exhibit 1) purportedly evidencing the sale of the land constitutes a valid and binding transfer of property rights when the vendor (plaintiff) was a minor at the time of signing.
    • Whether the alleged intimidation upon Paula Prado can render the transaction void or simply affect the evidentiary value of the document.

    Effect of Registration on the Validity of the Transfer

    • Whether the provisions of Section 50 of Act No. 496 imply that a contract, even if it embodies all legal requisites, does not bind the land unless proper registration is achieved.
    • How the absence of such registration impacts the rights of the parties involved in the transaction.

    Assessment of the Monetary Consideration

    • Whether the amount of P663.40, derived from adding accumulated interest on the earlier loan, was ever actually paid by the defendants as the purchase price of the land.
    • The implications of the lack of direct evidence of a monetary transaction in 1922 on the validity of the sale.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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