Case Summary (G.R. No. L-11872)
Procedural History
• April 9, 1913 – Petitioners sued in the Court of First Instance, Bulacan, seeking annulment of a May 17, 1910 deed (Exh. 3) and recovery of their shares plus rents.
• September 22, 1914 – Trial court dismissed the complaint, instructed petitioners to keep perpetual silence and taxed costs against them.
• Petitioners filed bills of exceptions; Supreme Court of the Philippines granted review on appeal.
Factual Background
• Margarita Espíritu (d. 1897) owned 48 ha in Panducot by inheritance from her father. In partition of her brother Luis’s estate, half fell to Margarita; her heirs (the Mercados) inherited one-half.
• May 25, 1894 – Margarita sold ~15 cavanes of seed-rice land to Luis for ₱2,000 (notarial instrument lost in the Revolution).
• May 14 and 20, 1901 – Wenceslao Mercado (Margarita’s widower and petitioners’ father) mortgaged or sold under pacto de retro ~6 cavanes to Luis for ₱375, later increased by loans to ₱600; confirmed in a notarial instrument (Exh. 1).
• 1901–1910 – Luis occupied and cultivated the entire 21 cavanes.
• May 17, 1910 – Petitioners and sisters, declaring themselves of legal age, executed a notarial deed (Exh. 3) ratifying prior transactions and conveying the full 21 cavanes to Luis for an “increase” of ₱400.
Claims and Relief Sought
Petitioners alleged:
- They were minors (ages 19 and 18) in May 1910 and lacked capacity; the sale is voidable.
- Luis used cajolery and fraud in procuring their signatures.
They sought annulment of Exh. 3, restitution of their hereditary land share, payment of uncollected produce (₱450 / yr.), and costs.
Defendant’s Response and Cross-Complaint
• Denied all allegations; asserted land area was only 21 cavanes and prior valid transfers.
• Cross-complaint alleged malicious suit causing ₱1,000 damages and asked that petitioners keep perpetual silence and pay damages plus costs.
• Petitioners answered, denying special defense and asserting the four-year period to annul for minority had not expired by the time they reached majority.
Central Legal Issues
- Were petitioners minors on May 17, 1910, and thus incapable of validly contracting?
- If minors, does their false representation of majority and near attainment thereof preclude annulment?
- Was there actionable fraud, violence, or intimidation vitiating Exh. 3?
Evidence on Plaintiffs’ Minority
• Original baptismal registers lost; petitioners offered a family copybook (Exh. A) showing births: Domingo 4 Aug 1890, Josefa 14 Jul 1891.
• Personal registration certificate (Exh. C) for Domingo in 1914 recorded age 23 in 1910.
• Testimony: deed Exh. 3 was read, translated into Pampangan, and signed after assurance of legal age. No contemporaneous challenge to age statements.
Analysis on Capacity and Estoppel
• Petitioners failed to produce certified baptismal records or other indisputable proof of minority.
• Even if under 21, they expressly represented majority in Exh. 3.
• Under Spanish law (Partidas; Civ. Code) and Spanish Supreme Court precedents, a minor who deceitfully asserts majority and induces the other party to rely thereon is estopped from disaffirming the contract.
• No credible evidence of fraud, coercion, or intimidation by Luis exists.
Validation of Prior
Case Syllabus (G.R. No. L-11872)
Facts of the Case
- Margarita Espiritu, sister of Luis Espiritu, died in 1897 owning a 48-hectare tract in barrio Panducot, Calumpit, Bulacan, as her paraphernal property.
- Her husband, Wenceslao Mercado, managed the property and, upon her death in 1896, her five children (Maria Consejo, Maria de la Paz, Domingo, Josefa, and Amalia Mercado y Espiritu) inherited half of the tract (approximately 24 hectares).
- In 1894, Margarita sold about 15 cavanes of seed rice land to her brother Luis for ₱2,000 (notarial sale of May 25, 1894).
- In May 1901, Wenceslao, acting as administrator of his minor children’s estate, mortgaged or pledged approximately six cavanes of seed rice land to Luis for ₱375 to meet his children’s needs (private instrument of May 14, 1901), later increased to ₱600.
- On May 17, 1910, Domingo and Josefa Mercado, together with their sisters Maria Consejo and Maria de la Paz, executed a notarial deed (Exhibit 3) ratifying prior transactions and absolutely selling the entire balance of 21 cavanes to Luis Espiritu for an additional ₱400, representing “an increase” over prior prices.
Procedural History
- April 9, 1913: Plaintiffs Domingo and Josefa Mercado filed suit in the Court of First Instance of Bulacan against Luis Espiritu; after his death, they amended the complaint to name his administrator, Jose Espiritu.
- September 22, 1914: The trial court dismissed the complaint, ordered plaintiffs to keep perpetual silence regarding the land, and taxed costs against them.
- Plaintiffs filed bills of exceptions, moved for reopening and a new trial (denied), and appealed to the Supreme Court of the Philippines.
Plaintiffs’ Contentions
- They claimed they and their sisters as sole heirs of Margarita Espiritu owned one-fourth of the original tract (approx. 11 ha 86 a 37 ca).
- They alleged Luis Espiritu fraudulently induced them, while minors, to sign Exhibit 3 for only ₱400, notwithstanding the land’s assessed value of ₱3,795 and annual yield equivalent to ₱450.
- They sought annulment of Exhibit 3 on grounds of minority