Title
Government of the Philippine Islands vs. Javier
Case
G.R. No. 30421
Decision Date
Aug 28, 1929
A deed transferring property for P2,000 was deemed invalid due to grossly inadequate consideration and Catalino Hechanova's vulnerable state. Javier, the son-in-law, was granted a P2,000 lien on the property for his payment.

Case Digest (G.R. No. 30421)

Facts:

The Government of the Philippine Islands v. Agustin Javier, G.R. No. 30421, August 28, 1929, the Supreme Court En Banc, Johns, J., writing for the Court.

The dispute arose in a land registration proceeding concerning certain lots formerly of Catalino Hechanova. Agustin Javier (claimant and appellant) produced Exhibit B, a deed dated April 15, 1919, purporting to convey to him an undivided one-half interest in the lots for a stated consideration of P2,000. The deed was signed by Catalino with a thumb mark because he was old and nearly blind; Javier is the son-in-law of Catalino. A notary who prepared the deed and Javier testified that P1,000 was paid at the time of execution and the remaining P1,000 was paid before Catalino’s death.

The trial court found the deed null and void for lack of consideration and refused to register title in Javier’s name, instead decreeing registration in the names of Catalino Hechanova and Vicenta Guriesa. Javier appealed, asserting the deed was valid and that he should be registered as owner of one-half the lots. The Government of the Philippine Islands was the applicant in the proceeding below; Cornelia Hechanova appeared as claimant and appellee opposing Javier’s claim.

On appeal to the Supreme Court (Rule 45 review of the lower court’s decree in the land registration case), the Court reviewed the factual conflicts concerning payment, the circumstances of execution, and the intent of Catalino. The Court weighed testimony that the P2,000 was in fact paid against evidence that Javier ...(Pro-only)

Issues:

  • Was Exhibit B a valid conveyance of legal title to Agustin Javier?
  • If Exhibit B is not an effective conveyance, is Javier nonetheless entitled to a preferred lien for P2,000 on an undivided one-half interest in the lots, and what r...(Pro-only)

Ruling:

  • (Pro-only)

Ratio:

  • (Pro-only)

Doctrine:

  • (Pro-only)

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