Case Digest (G.R. No. L-11872) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Domingo Mercado and Josefa Mercado v. Jose Espiritu, G.R. No. 11872, decided December 1, 1917, the Court of First Instance of Bulacan dismissed the complaint of siblings Domingo and Josefa Mercado against Jose Espiritu, administrator of the estate of their uncle Luis Espiritu. The plaintiffs were heirs of Margarita Espiritu, sister of the deceased Luis, who died in 1897 owning 48 hectares in Panducot, Calumpit, Bulacan. In 1894 Margarita sold 15 cavanes of seed rice land to her brother Luis for ₱2,000. In 1901 their father, Wenceslao Mercado, in his capacity as administrator of his minor children’s property, mortgaged another 6 cavanes of land to Luis for ₱375 (later increased to ₱600). In 1910 Domingo and Josefa (together with two sisters) executed a notarial deed (Exhibit 3) acknowledging prior transactions and selling the entire 21 cavanes of land to Luis for an “increase” of ₱400. The plaintiffs later claimed they were minors in 1910, that Luis secured their signatures by Case Digest (G.R. No. L-11872) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and procedural history
- Plaintiffs and appellants Domingo and Josefa Mercado, children and heirs of Margarita Espiritu, filed suit on April 9, 1913 in the Court of First Instance of Bulacan against Luis Espiritu; after his death the suit was amended against his administrator, Jose Espiritu.
- Plaintiffs alleged that a 48-hectare tract in Panducot, Calumpit, Bulacan—paraphernal property of their mother—had been held by their family since 1897; that Luis Espiritu, by fraud and cajolery, induced Domingo and Josefa to sign a deed of sale for ₱400 in about 1910, although the land was valued at ₱3,795; and they prayed to annul the sale, recover their one-quarter shares plus uncollected products (₱450 per annum), and costs.
- Defendant’s answer and cross-complaint
- Denial of all allegations; special defense that:
- In 1894 Margarita Espiritu sold 15 cavanes for ₱2,000 to Luis;
- In 1901 Wenceslao Mercado (husband and administrator) sold under pacto de retro another 6 cavanes for ₱375 and borrowed additional ₱600;
- On May 17, 1910, the four Mercado children, declaring themselves of legal age, ratified prior transactions and sold the entire 21-cavane parcel for ₱400.
- Cross-complaint sought an order of perpetual silence regarding the land, ₱1,000 damages to the estate, and costs. Plaintiffs denied and urged annulment on grounds of minority within four-year period.
- Trial evidence
- Proof of minority: lost baptismal registers; plaintiffs’ sister recognized a copybook entry showing births on August 4, 1890 (Domingo) and July 14, 1891 (Josefa); 1910 cedula and 1914 personal registry also indicated ages under majority.
- Witnesses for defendant: notary Tanjutco testified plaintiffs represented themselves as of age and signed after translation; relatives testified as to land area, yields, and management by Luis Espiritu; no evidence of fraud or intimidation in 1910 deed.
- Rebuttal: plaintiffs denied procuring the 1910 deed through fraud or that witnesses were present; no supplemental proof of actual minority was introduced beyond copybook entries.
Issues:
- Whether Domingo and Josefa Mercado were minors on May 17, 1910 when they executed the deed of sale (Exhibit 3) and thus lacked capacity to contract.
- If they were minors, whether their false representation of majority in the 1910 instrument estops them, within the four-year annulment period (Civ. Code, arts. 1263, 1300), from seeking rescission.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)