Case Digest (G.R. No. 225141) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Julian Francisco (Substituted by His Heirs) vs. Pastor Herrera, the petitioners, heirs of Eligio Herrera, Sr., challenged the sale of two parcels of land in Barangay San Andres, Cainta, Rizal. On January 3, 1991, the vendor sold the first lot (500 sq m., TD No. 01-00495) to petitioner for ₱1,000,000, and on March 12, 1991, he sold the second lot (451 sq m., TD No. 01-00497) for ₱750,000, both paid in installments. Respondent Pastor Herrera, claiming prior ownership of the second parcel since 1973 and co-ownership of the first as heir of his mother, filed Civil Case No. 92-2267 in the RTC of Antipolo City to annul both sales. He asserted that at the time of sale, his father suffered from senile dementia, rendering him incapable of consent, and that the contract price was grossly inadequate. The trial court declared the deeds null and void, ordered reconveyance of the properties, and refund of ₱1,750,000, a decision the Court of Appeals affirmed on August 30, 1999. The Supreme Case Digest (G.R. No. 225141) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Properties
- Petitioner: Julian Francisco (substituted by his heirs) vs. Respondent: Pastor Herrera.
- Original owner: Eligio Herrera, Sr.; two parcels in Barangay San Andres, Cainta, Rizal (500 sq m., TD No. 01-00495; 451 sq m., TD No. 01-00497).
- Sale Transactions
- January 3, 1991: Petitioner bought TD No. 01-00495 for ₱1,000,000, paid in installments (Nov. 30, 1990 – Aug. 10, 1991).
- March 12, 1991: Petitioner bought TD No. 01-00497 for ₱750,000.
- Proceedings Below
- Respondent filed Civil Case No. 92-2267 claiming prior sale (1973) of the second parcel; co-ownership of the first; senile dementia of vendor vitiating consent.
- Petitioner pleaded estoppel and ratification by respondent’s acceptance of payments.
- RTC (Nov. 14, 1994): Declared both deeds null and void; ordered return of lots and refund of ₱1,750,000; denied counterclaim.
- CA (Aug. 30, 1999): Affirmed RTC decision in toto.
Issues:
- Whether the contracts of sale are void ab initio or merely voidable and hence susceptible to ratification.
- Whether respondent’s acceptance of installment payments constituted implied ratification of the contracts.
- Whether the alleged prior sale of one parcel and co-ownership of the other rendered the transactions void.
- Whether the findings on senile dementia and gross inadequacy of consideration violate due process.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)