Case Digest (G.R. No. L-1720)
Case Digest (G.R. No. L-1720)
Facts:
Sia Suan and Gaw Chiao, petitioners, vs. Ramon Alcantara, respondent, G.R. No. L-1720, March 04, 1950, the Supreme Court En Banc, Paras, J., writing for the Court.On August 3, 1931, Rufino Alcantara and his sons Damaso and Ramon executed a deed of sale conveying five parcels of land to Sia Suan. The deed recited that Ramon was of legal age, although he was in fact 17 years, 10 months and 22 days old. On August 27, 1931, Francisco Alfonso, attorney for Ramon, wrote to Gaw Chiao (husband of Sia Suan) informing him that Ramon was a minor and disavowing the contract. Shortly thereafter Ramon executed an affidavit in the office of Jose Goraea (attorney for Gaw Chiao) ratifying the deed; on that occasion Ramon received P500 from Gaw Chiao.
Between those events Sia Suan sold one of the lots to Nicolas Azores (later inherited by Antonio Azores). On August 8, 1940, Ramon filed suit in the Court of First Instance of Laguna to annul the deed insofar as it affected his undivided share in the parcels covered by Certificates of Title Nos. 751 and 752. The action named Sia Suan and Gaw Chiao, Antonio Azores, Damaso Alcantara and Rufino Alcantara as defendants. After trial, the Court of First Instance absolved all defendants.
The Court of Appeals reversed the trial court, holding that the deed was not binding on Ramon due to his minority; it ordered reconveyance of an undivided one‑fourth interest in the lot covered by C.T. No. 752 and awarded Ramon P1,750 with legal interest in lieu of his share in the lot sold to Antonio Azores, plus costs. The Court of Appeals noted that the appellees had been informed of Ramon’s minority within one month but nonetheless concluded the contract was void as to him.
Sia Suan and Gaw Chiao brought the case to the Supreme Court by certiorari (appeal by certiorari), contesting the Court of Appeals’ reversal and the relief awarded to Ramon.
Issues:
- Whether the deed of sale executed by Ramon while a minor is binding on him because he represented himself to be of legal age and thereby is estopped from disaffirming the contract.
- Whether the nature of the consideration (a pre‑existing indebtedness) or the circumstances of notice and delay (letter notifying minority, subsequent ratification, and passage of time) prevent the sellers from invoking minority to annul the deed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)