Title
De Guia vs. Presiding Judge, Regional Trial Court Branch 12, Malolos, Bulacan
Case
G.R. No. 161074
Decision Date
Mar 22, 2010
Heirs of Primitiva contested 1979 mortgage and lease documents, alleging duress and lack of consideration. SC upheld validity, ruling documents were executed with consideration and foreclosure threat was lawful.

Case Summary (G.R. No. 189774)

Background and Legal Transaction History

The case revolves around multiple transactions involving the property in question. On August 8, 1973, Primitiva executed a mortgage document in favor of respondents Spouses Morte for a loan of P20,000. A year later, on February 15, 1974, she sold the property to Spouses Villarico for P33,000. Following this, on February 14, 1977, the Spouses Villarico sold the property back to Primitiva for the same amount. On March 26, 1977, Primitiva sold it again to the Spouses Villarico for P180,000, who later invoked a mortgage with Spouses Morte for another loan on March 28, 1977.

Court Proceedings and Claims

The conflict erupted when Primitiva failed to repay the substantial loan of P500,000 secured by a mortgage executed on November 10, 1979. Consequently, the Spouses Morte initiated an extrajudicial foreclosure action. In response, on February 17, 1986, De Guia filed an Amended Complaint in the Regional Trial Court seeking to annul the mortgage and a lease agreement, alleging that they were executed under duress and lacked valuable consideration.

Findings of the Regional Trial Court

The Regional Trial Court ruled against the petitioners, affirming the validity of the mortgage and the lease agreement. It stated that the documents were executed with full understanding and that any threats made by the respondents, related to the foreclosure application, did not negate consent as they were legally justified. The petitioners attempted to claim coercion but failed to demonstrate this adequately, as a threat of foreclosure was a legal claim.

Court of Appeals and Final Decision

Upon appeal, the Court of Appeals upheld the RTC's ruling, concluding that the transactions dated November 10, 1979, were not void or simulated. The appellate court noted that due to the acknowledgment of existing debts, the waiver of prior transactions, and the financial exchange involved in the execution of the questioned documents, the agreements held merit.

Legal Implications and Arguments

The issues raised by the petitioners included the validity of the transactions, the supposed absence of registration affecting their enforceability, and whether the Court of Appeals erred in validating the contested documents. However, the S

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