Case Summary (G.R. No. L-11872)
Factual background and title history
The disputed property originated in title acquired by Lucas Espiritu in 1891 and later devolved among his descendants. In the partition, a large parcel was allotted to siblings Luis and Margarita Espiritu in equal shares. Margarita, married to Wenceslao Mercado, had five children (including the plaintiffs) who, by succession on Margarita’s death, inherited one-half of Margarita’s share. The plaintiffs claimed entitlement to a specific hereditary portion (two-fourths of Margarita’s half, i.e., one-fourth of the whole parcel), which they quantified in hectares.
Prior transactions affecting the land (1894–1901)
Documentary evidence admitted at trial showed that on May 25, 1894 Margarita conveyed by sale to her brother Luis a portion of the land (described as approximately 15 cavanes of seed). Later, Wenceslao, acting for himself and his children, executed a notarial instrument of May 20, 1901 (Exhibit 1) acknowledging the earlier sale and ratifying facts concerning the loss of the original documents (protocols having been burned during the revolution). On May 14, 1901, Wenceslao also pledged or mortgaged an additional parcel (about 6 cavanes of seed) to Luis (Exhibit 2) to raise funds, the record showing sums borrowed aggregating P600.
The 1910 instrument (Exhibit 3) and plaintiffs’ challenge
On May 17, 1910 the plaintiffs (Domingo, Josefa and their sisters) executed a notarial deed (Exhibit 3) which acknowledged the prior sale and pledge transactions and purported to sell absolutely and in perpetuity to Luis the parcel described as equal to that sown by 21 cavanes of seed, in consideration of an “increase” of P400. The plaintiffs sought annulment of Exhibit 3 on the grounds (1) they were minors on the date of execution and thus lacked legal capacity to sell, and (2) the deed was procured by deceit/fraud.
Defendant’s position and cross-complaint
The defendant (administrator) denied the plaintiffs’ allegations, asserted that the land involved comprised only about 21 cavanes (and not the larger acreage alleged by plaintiffs), and maintained the validity of the prior transfer documents. He pleaded that the May 17, 1910 deed ratified and confirmed the prior sale and mortgage and that Luis (and now his estate) was lawfully in possession. He cross-complained for malicious prosecution, asserted damages, and sought a judgment requiring the plaintiffs to keep perpetual silence.
Evidence on age, credibility, and lost records
The plaintiffs relied on family testimony and a copybook (Exhibit A) purportedly showing birth dates (Domingo: August 4, 1890; Josefa: July 14, 1891) and their contention that they were minors on May 17, 1910 (ages alleged as 19 and 18). The parish baptismal records for 1890–1891 were destroyed; a personal registration certificate (cedula) for Domingo showing age 23 in 1914 (Exhibit C) and another cedula (Exhibit B) were in the record, but the plaintiffs did not produce certified baptismal copies or other conclusive proof of minority. The notary before whom Exhibit 3 was drawn testified that the grantors represented themselves to be of legal age and that the deed was read and translated before signature. Other witnesses corroborated that Luis had been in actual possession and that cultivation and administration were directed by him over many years.
Legal and evidentiary findings on the prior documents
The Court treated Exhibit 1 (the 1901 notarial instrument reflecting the 1894 sale) as a public document with probative force under Civil Code art. 1218, and found it reliable—particularly because Wenceslao (the plaintiffs’ father) had executed it and thereby corroborated the prior sale of the 15-cavane parcel. Exhibit 2 (the 1901 pledge/mortgage for the 6-cavane portion) likewise was not successfully impeached and formed part of the chain of title and transactions acknowledged by Exhibit 3. The Court thus found that, by virtue of the 1894 sale and the 1901 pledge/mortgage, Luis had maintained possession and titles by legal instruments covering the total 21 cavanes.
Capacity, estoppel, and the Court’s legal reasoning
The decision addressed two central legal questions posed by the plaintiffs: (1) whether they were minors on May 17, 1910, and (2) if they were minors who represented themselves as of legal age, whether they could annul the sale within the statutory period. The Court observed that the plaintiffs failed to present conclusive proof of minority (baptismal certificates were missing and the copybook was insufficient). Moreover, Exhibit 3 contained express statements by the plaintiffs declaring they were of legal age when they executed it. The Court invoked established doctrinal authority (including the Partidas and Spanish Supreme Court precedents cited) that sales of real estate by persons who falsely represent themselves as of legal age may be upheld where the other party has good reason to believe the grantor was of age. Applying that doctrine and the facts, the Court concluded that Exhibit 3 was binding at least insofar as it acknowledged prior valid transactions and that the plaintiffs could not nullify rights already vested in the purchaser without adequate proof of incapacity or of fraud.
Application to the specific claims: fraud, redemption, and compensation
On the fraud claim, the Court found no evidence of deceit, violence, or intimidation by Luis in procuring signatures to Exhibit 3; the notary’s testimony and the surrounding facts did not support a finding of undue influence or fraud. On the pa
...continue readingCase Syllabus (G.R. No. L-11872)
Procedural History
- Action commenced by complaint dated April 9, 1913, filed in the Court of First Instance of Bulacan by counsel for Domingo and Josefa Mercado against Luis Espiritu; complaint later amended to name Jose Espiritu as administrator of the estate of the deceased Luis Espiritu after Luis's death.
- Trial in the Seventh Judicial District resulted in judgment on September 22, 1914, dismissing the plaintiffs' complaint, ordering them to keep perpetual silence with respect to the litigated land, and charging them with the costs of suit.
- Plaintiffs filed bill of exceptions and appealed by exceptions; motion for reopening and new trial was overruled; bill of exceptions approved and transmitted to the Supreme Court.
- Defendant filed an answer denying allegations and asserted special defenses; he also filed a cross-complaint seeking P1,000 in damages for alleged malicious and unfounded prosecution and a decree ordering plaintiffs to keep perpetual silence; plaintiffs filed a reply denying facts in the cross-complaint and asserted minority defense and prescription as special defenses.
Parties and Relationships
- Plaintiffs: Domingo Mercado and Josefa (Josefa/Josef a in record) Mercado, together with sisters Maria del Consejo (Concepcion/Consejo), Maria de la Paz (Paz), and Amalia; children and sole heirs of Margarita Espiritu.
- Plaintiffs’ parents: Margarita Espiritu (deceased 1896/1897 as stated variably), married to Wenceslao Mercado y Arnedo Cruz (father; deceased about 1904).
- Defendant/Appellee: Jose Espiritu, administrator of the estate of the deceased Luis Espiritu (the purchaser in contested transactions).
- Relationship: Margarita Espiritu was sister of Luis Espiritu; Luis was uncle of the plaintiffs; Lucas Espiritu was original titleholder who obtained title by composition in 1891 and from whom the contiguous parcels derive.
Subject Matter and Land Description
- Litigated property: tract situated in the barrio of Panducot, municipality (pueblo) of Calumpit, Bulacan; various descriptions in pleadings and exhibits locate boundaries by adjoining owners and Sapang-Maitu stream.
- Area contested: plaintiffs claimed one-half of the parental allotment yielded two-fourths of one large parcel equating to 11 hectares, 86 ares and 37 centares (their share as two-fourths of the land left by Margarita); defendant contended the entire parcel in controversy equated to an area commonly sown with 21 cavanes of seed rice.
- Documentary references describe constituent parcels: a parcel of about 15 cavanes of seed rice sold by Margarita to Luis in 1894; a remainder parcel of about 6 cavanes of seed rice pledged/mortgaged or later sold.
Plaintiffs’ Allegations and Relief Sought
- Plaintiffs averred they and sisters were sole heirs of Margarita Espiritu; Margarita left paraphernal property of 48 hectares (alleged in amended complaint) and hereditary portion thereafter held by plaintiffs and sisters via their father Wenceslao.
- Plaintiffs alleged that about 1910 Luis Espiritu induced Domingo and Josefa by cajolery and fraud to sign a deed of sale (Exhibit 3) of the land for P400, though land was assessed at P3,795.
- Plaintiffs asserted that one-half of the land belonged to Margarita, and one-half of that share (one-fourth of whole) to plaintiffs; plaintiffs alleged productive capacity of their two-plaintiff share was 180 cavanes of rice per annum, at P2.50 per cavan = P450 per annum, and that Luis had received such products from 1901 until his death.
- Relief sought: annulment of the sale executed by plaintiffs to Luis, restitution and delivery of the plaintiffs’ shares in partition, recovery of uncollected products since 1901 or their equivalent (P450 per annum), and costs.
Defendant’s Answer, Special Defenses and Cross-Complaint
- Defendant denied plaintiffs’ allegations and specially alleged factual history of antecedent conveyances:
- May 25, 1894: Margarita Espiritu sold to Luis Espiritu a portion of the land (about 15 cavanes of seed) for P2,000 (notarial instrument; original lost).
- May 14, 1901: Wenceslao Mercado, the plaintiffs’ father, pledged/mortgaged to Luis for P375 a part of the land (about 6 cavanes of seed) — to meet maintenance expenses of his children.
- Wenceslao later borrowed additional sums from Luis, aggregating P600.
- May 20, 1901: Wenceslao executed notarial instrument (Exhibit 1) in his name and in those of his minor children acknowledging the 1894 sale.
- May 17, 1910: Plaintiffs (alleged to be of legal age) together with sisters executed notarial instrument Exhibit 3, ratifying the pacto de retro and selling absolutely and perpetually to Luis the property for P400 as an increase to previous purchase price, yielding an aggregate of P2,600 or as stated P2,600 then P400 increase.
- Defendant’s cross-complaint alleged plaintiffs’ suit was unfounded and malicious, caused losses and damages of P1,000 to the intestate estate of Luis, and prayed for perpetuance of plaintiffs’ silence regarding the land, payment of P1,000, and costs.
Central Issues Presented to the Court
- Whether plaintiffs Domingo and Josefa were minors on May 17, 1910, when they executed Exhibit 3, and thus incapable to validly sell their property.
- If they were minors, whether a minor who falsely represents that he is of legal age and executes a deed can within the legal period seek annulment of the instrument for defects invalidating the contract (reference to Civ. Code arts. 1263 and 1300).
- Whether Exhibit 3 is null and void for reasons of minority, fraud, deceit, or coercion.
- Whether the antecedent instruments (Exhibits 1 and 2) and the chain of possession and titles vested lawful ownership in Luis and his estate and negated plaintiffs’ recovery.
- The validity and evidentiary weight of public and private documents presented (Exhibits 1, 2, 3, A, B, C, D).
Evidence Adduced at Trial — Documents and Witnesses
- Documentary evidence:
- Exhibit D: title showing Lucas Espiritu obtained composition title in 1891 to three adjoining parcels totaling 75 hectares, 25 ares and 59 centares.
- Notarial instrument of May 25, 1894 (sale by Margarita to Luis for P2,000) — original lost but attested in Exhibit 1.
- Exhibit 1: notarial instrument of May 20, 1901 signed by Wenceslao in his own name and in those of his minor children acknowledging the 1894 sale.
- Exhibit 2: private document dated May 14, 1901 — pledge/mortgage by Wenceslao to Luis for P375 covering about 6 cavanes of seed; signature identified by plaintiff Consejo Mercado.
- Exhibit 3: notarial deed of May 17, 1910 executed by plaintiffs and sisters selling in perpetuity to Luis for P400 (describes parcel as area equal to that sown with 21 cavanes of seed).
- Exhibit A: copybook pages 396–397 preserved by father Wenceslao purporting to show baptisms; testimony placed birthdates for Domingo (Aug 4, 1890) and Josefa (July 14, 1891) on these pages.
- Exhibit B: cedula (personal registration) for Domingo for 1910 showing age of 23 (testimony describes Luis may have procured this).
- Exhibit C: personal registration certificate of Domingo for 1914 indicating age 23 in 1914.
- Witnesses for plaintiffs and defendant:
- Maria Consejo Mercado: testified regarding Exhibit A, identification of birthdates, family movements to Manila after father’s death, and circumstances of signing