G.R. No. 17905 - People vs. Moran

JULIAN FRANCISCO (SUBSTITUTED BY HIS HEIRS, NAMELY: CARLOS ALTEA FRANCISCO; THE HEIRS OF LATE ARCADIO FRANCISCO, NAMELY: CONCHITA SALANGSANG-FRANCISCO (SURVIVING SPOUSE), AND HIS CHILDREN NAMELY: TEODULO S. FRANCISCO, EMILIANO S. FRANCISCO, MARIA THERESA S. FRANCISCO, PAULINA S. FRANCISCO, THOMAS S. FRANCISCO; PEDRO ALTEA FRANCISCO; CARINA FRANCISCO-ALCANTARA; EFREN ALTEA FRANCISCO; DOMINGA LEA FRANCISCO-REGONDON; BENEDICTO ALTEA FRANCISCO AND ANTONIO ALTEA FRANCISCO), PETITIONER purchased land from Eligio Herrera, Sr.
PASTOR HERRERA, RESPONDENT was one of the children and heirs of Eligio Herrera, Sr.

The vendor, Eligio Herrera, Sr., was declared owner of two parcels in Barangay San Andres, Cainta, Rizal, covered by Tax Declaration Nos. 01-00495 (500 sq. m.) and 01-00497 (451 sq. m.).
Respondent alleged prior ownership over the parcel covered by TD No. 01-00497 by virtue of a sale in his favor since 1973.
Respondent claimed the parcel covered by TD No. 01-00495 was subject to co-ownership among the heirs of the deceased wife, Francisca A. Herrera, who died intestate on April 2, 1990.

On January 3, 1991, petitioner bought the parcel under TD No. 01-00495 for P 1,000,000; installments were paid from November 30, 1990 to August 10, 1991.
On March 12, 1991, petitioner bought the parcel under TD No. 01-00497 for P 750,000.
Respondent and his siblings negotiated with petitioner to increase the purchase price, but petitioner refused.
Respondent received installment payments and engaged in negotiations seeking a higher price prior to filing suit.

Respondent alleged that at the time of sale Eligio, Sr. suffered from senile dementia and was therefore incapacitated to give consent.
Petitioner pleaded estoppel and ratification, asserting respondent effectively ratified the sales by receiving the consideration.

Respondent filed a complaint for annulment of sale with the Regional Trial Court of Antipolo City, docketed as Civil Case No. 92-2267.
On November 14, 1994, the RTC declared the deeds of sale null and void, ordered return of the ...(Subscriber-Only)

Whether the contracts of sale covering TD Nos. 01-00495 and 01-00497 were void ab initio or merely voidable and thus susceptible of ratification.

Whether respondent's acceptance of installment payments and negotiations for higher price constituted ratification of the contracts.
Whether senile dementia of the vendor rendered the contracts void rather than voidable under applicable provisions of the Civil Code.
Whether respondent's assertions of prior sale (1973) and co-ownership defeated the validity o...(Subscriber-Only)