G.R. No. L-49549 - Chua-Qua vs. Clave

Plaintiff: Benedicto M. Javier, acting as the administrator of the Estate of Eusebio Cruz.
Respondents: Dominga Vda. de Cruz and her children (Leonila, Roman, Eliseo, Liberata, and Melecío), who are heirs and claimants in the disputed property.

The suit was filed to declare null and void a deed of sale (Exhibit A) concerning a portion of land.
The land in question is located in Barrio San Isidro, Taytay, Rizal, with an area of 182,959 square meters, though the deed purports to sell only 26,577 square meters for the sum of P700.00.
The plaintiff alleged that the deed was fraudulent, executed without valid consent and adequate consideration from the decedent, Eusebio Cruz.

Eusebio Cruz, who died on February 2, 1941, at nearly 100 years of age, was the alleged owner of the disputed property inherited from his forebears.
Prior to his death, Eusebio Cruz executed a deed of sale allegedly in favor of his servant, Delfin Cruz, on January 16 or January 17, 1941.
The conditions surrounding the execution of the deed were highly questionable:

Eusebio Cruz was in a weak and deteriorating physical state, on the verge of death.
He was incapable of confirming the contents of the document, as evidenced by his inability to answer questions regarding the legitimacy of the signature/thumbmark.
Testimony (from Leonardo Valle, son of the notary public) revealed that Eusebio Cruz could hardly respond due to his frail condition, raising doubts on whether his thumbmark was voluntarily affixed.

The deed of sale was executed under conditions of fraud, deceit, and without proper consent or receipt of genuine consideration.
The thumbmark was affixed involuntarily by Eusebio Cruz, who did not comprehend the nature of the transaction.
The testimony of witnesses supported the contention that the transaction was executed in bad faith, exploiting the elderly decedent.

The defendants argued that Eusebio Cruz was legally married to Isidora Santos and that the property was acquired jointly by the spouses.
They further claimed that the deed of sale was valid, having been notarized and registered per legal requirements (e.g., under Act No. 3344), and that the adverse possession had been public, peaceful, and continuous for over 18 years.

The Court of First Instance rendered a decision in favor of the respondents, sustaining the validity of the deed of sale.
The court noted the presumption of regularity in official acts and private transactions, finding the documentary evidence persuasive despite wavering testimony from the plaintiff.

The Court of Appeals certified the case to the Supreme Court due to the high property valuation (exceeding half a million pesos).
The petitioner subsequently raised several errors with the lower court’s handling of evidence and legal issues, particularly emphasizing the lack of true consent and the gross inadequacy of the consideration provided.

Inclusion of extraneous matters not substantiated by evidence in the decision.
Failure to acknowledge that the disputed land was originally acquired by Eusebio Cruz through inheritance and thus belonged to his intestate estate.
Erroneous admission of secondary evidence regarding the acquisition of the land.
Improper validation of the deed of sale and the accompanying affidavit despite the evident lack of consent and consideration from a nearly incapacitated Eusebio Cruz.
Incorrect presumption in favor of the validity of the deed, without fully considering the manifest inadequacy of the sale price and the circumstances surrounding its execution.

Whether the deed of sale, which purportedly transferred only a part of the land, was executed with the free and informed consent of Eusebio Cruz.
Whether the thumbmark affixed by Eusebio Cruz can be deemed a valid expression of his consent given his advanced age and compromised condition.

Whether P700.00 was a genuine, fair, and sufficient consideration for a parcel of land substantially larger and more valuable.
If the gross inadequacy of the consideration reflects a manifestation of fraud or undue influence on the part of Delfin Cruz.

Whether the lower court erred in preferring documentary evidence over credible testimonial evidence concerning the condition and capacity of Eusebio Cruz.
Whether the evidence of incapacity and lack of comprehension by Eusebio Cruz should have led to the voiding of the deed of sale.

Whether there is sufficient evidence to support the claim that the execution of the deed was tainted by fraud, deceit, and exploitation of a vulnerable individual.
Whether the alleged collusion by Delfin Cruz and other parties invalidates the transaction.