G.R. No. 126376, 20 November 2003


Sought to be declared null and void ab initio are certain deeds of sale of real property executed by defendant parents Leonardo Joaquin and Feliciana Landrito in favor of their co-defendant children and the corresponding certificates of title issued in their names because of:

  1. a) Firstly, there was no actual valid consideration for the deeds of sale xxx over the properties in litis;
  2. b) Secondly, assuming that there was consideration in the sums reflected in the questioned deeds, the properties are more than three-fold times more valuable than the measly sums appearing therein;
  3. c) Thirdly, the deeds of sale do not reflect and express the true intent of the parties (vendors and vendees); and
  4. d) Fourthly, the purported sale of the properties in litiswas the result of a deliberate conspiracy designed to unjustly deprive the rest of the compulsory heirs (plaintiffs herein) of their legitime.

Defendants, on the other hand, aver (1) that plaintiffs do not have a cause of action against them as well as the requisite standing and interest to assail their titles over the properties in litis; (2) that the sales were with sufficient considerations and made by defendants parents voluntarily, in good faith, and with full knowledge of the consequences of their deeds of sale; and (3) that the certificates of title were issued with sufficient factual and legal basis.


Whether the Deeds of Sale are void for the gross inadequacy of price.


No. Petitioners failed to prove any of the instances mentioned in Articles 1355 and 1470 of the Civil Code which would invalidate, or even affect, the Deeds of Sale. Indeed, there is no requirement that the price is equal to the exact value of the subject matter of sale. All the respondents believed that they received the commutative value of what they gave.

* Case digest by   Prince Dave C. Santiago, LLB-1, Andres Bonifacio Law School, SY 2017-2018