Title
Suan vs. Alcantara
Case
G.R. No. L-1720
Decision Date
Mar 4, 1950
A minor misrepresented his age in a 1931 land sale, later ratified it, and sought annulment. The Supreme Court upheld the sale, citing estoppel and valid consideration, despite his minority.
minor
annul
deed of sale
A

Case Summary (G.R. No. L-1720)

Factual Background

On August 3, 1931, Rufino Alcantara and his sons, including Ramon Alcantara, executed a deed of sale conveying five parcels of land to Sia Suan. The deed recited that Ramon Alcantara was of legal age, but he was in fact seventeen years, ten months and twenty-two days old at the time. On August 27, 1931, attorney Francisco Alfonso notified Gaw Chiao, husband of Sia Suan, that Ramon was a minor and sought to disavow the contract; shortly thereafter Ramon executed an affidavit ratifying the sale in the office of Gaw Chiao’s counsel and received P500 from Gaw Chiao. In the interim, Sia Suan sold one parcel to Nicolas Azores, later inherited by Antonio Azores.

Trial Court Proceedings

On August 8, 1940, Ramon Alcantara sued in the Court of First Instance of Laguna to annul the deed of sale insofar as his undivided share in two parcels covered by certificates of title Nos. 751 and 752. The action named as defendants Sia Suan, Gaw Chiao, Antonio Azores, Damaso Alcantara, and Rufino Alcantara. After trial the Court of First Instance absolved all defendants.

Court of Appeals Decision

The Court of Appeals reversed the trial court. It held that the deed of sale was not binding on Ramon Alcantara because he was a minor when it was executed and therefore lacked capacity to contract. The Court of Appeals ordered Sia Suan to pay Ramon Alcantara PHP 1,750.00 with legal interest from December 17, 1931 in lieu of his share in the lot sold to Antonio Azores, and to reconvey an undivided one-fourth interest in the lot originally covered by certificate of title No. 752, plus costs.

Issues Presented

The case presented whether the deed of sale executed by a minor who was falsely represented in the instrument to be of legal age bound the minor, whether prompt notice of minority and subsequent ratification affected the result, whether the vendor’s consideration being a pre-existing debt prevented annulment, and whether defenses of laches or statutes of limitation barred relief.

Petitioners' Contentions

Sia Suan and Gaw Chiao argued that they relied on the positive recital in the deed that Ramon Alcantara was of age and that under the doctrine applied in Mercado and Mercado vs. Espiritu a minor who represents himself to be of age is estopped from disaffirming the sale. They further contended that the consideration consisted largely of a pre-existing obligation of Rufino Alcantara and that the appellants suffered detriment sufficient to enforce the contract.

Respondent's Contentions

Ramon Alcantara maintained that the deed was void as to his interest because a minor cannot give valid consent to a contract. He asserted that notice of his minority and his subsequent affidavit did not estop him, and that the deed was properly subject to annulment. The Court of Appeals accepted that view and found the sale voidable.

Supreme Court Ruling

The Supreme Court reversed the judgment of the Court of Appeals and absolved Sia Suan and Gaw Chiao from the complaint, with costs against Ramon Alcantara. The Court held that the deed was binding on Ramon and that he was estopped from disaffirming the sale.

Supreme Court Reasoning

The Court observed that the deed of sale expressly recited that Ramon Alcantara was of legal age and that the appellants relied on that recital. The Court invoked the doctrine in Mercado and Mercado vs. Espiritu that a sale by a minor who falsely represents himself to be of age will be enforced against the minor where the purchaser is led thereby to his detriment. The Court found that the consideration for the conveyance was a pre-existing indebtedness of Rufino Alcantara, which constituted a valid consideration and was sufficient to support the contract even though no cash was initially parted with. The Court rejected the Court of Appeals’ reliance on the defendants’ later notice of minority and on laches or promptness of disaffirmance, reasoning that a belated notice of minority does not defeat an estoppel based on the minor’s earlier misrepresentation. The Court thus concluded that the minor’s misrepresentation estopped him from annulling the sale.

Concurring Opinions

Justice Padilla concurred in the result but disagreed with the majority’s application of estoppel. He reasoned that under the Civil Code a contract requires the consent of both parties (art. 1261, Civil Code) and a minor cannot validly give consent; therefore the deed was null insofar as Ramon’s interest was concerned. He observed that Las Siete Partidas provision relied on in the Spanish precedents and in Mercado and Mercado vs. Espiritu has no counterpart in the Civil Code, and he would not apply estoppel to validate an act void for lack of consent. Justice Padilla further noted that the action as filed on August 6, 1940 would be barred by article 1301 of the Civil Code because it was not brought within four years after the minor reached majority. Justices Moran and Bengzon concurred with Justice Padilla.

Dissenting

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