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Buenaventura vs. CA
Buenaventura vs. CA
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SPOUSES
BERNARDO
BUENAVENTURA
and
CONSOLACION JOAQUIN, SPOUSES JUANITO EDRA
and NORA JOAQUIN, SPOUSES RUFINO VALDOZ and
EMMA
JOAQUIN,
and
NATIVIDAD
JOAQUIN,
petitioners, vs. COURT OF APPEALS, SPOUSES
LEONARDO JOAQUIN and FELICIANA LANDRITO,
SPOUSES
FIDEL
JOAQUIN
and
CONCHITA
BERNARDO,
SPOUSES
TOMAS
JOAQUIN
and
SOLEDAD ALCORAN, SPOUSES ARTEMIO JOAQUIN
and SOCORRO ANGELES, SPOUSES ALEXANDER
MENDOZA and CLARITA JOAQUIN, SPOUSES
TELESFORO CARREON and FELICITAS JOAQUIN,
SPOUSES DANILO VALDOZ and FE JOAQUIN, and
SPOUSES GAVINO JOAQUIN and LEA ASIS,
respondents.
Remedial Law Actions PartyinInterests Petitioners are
interested in the properties subject of the Deeds of Sale, but they
have failed to show any legal right to the properties An action
must be prosecuted in the name of the real partyininterest.It is
evident from the records that petitioners are interested in the
properties subject of the Deeds of Sale, but they have failed to
show any legal right to the properties. The trial and appellate
courts should have dismissed the action for this reason alone. An
action must be prosecuted in the name of the real partyin
interest.
Civil Law Contracts Sale If there is a meeting of the minds
of the parties as to the price, the contract of sale is valid despite the
manner of payment, or even the breach of that manner of payment.
A contract of sale is not a real contract, but a consensual
contract. As a consensual contract, a contract of sale becomes a
binding and valid contract upon the meeting of the minds as to
price. If there is a meeting of the minds of the parties as to the
price, the contract of sale is valid, despite the manner of payment,
or even the breach of that manner of payment. If the real price is
not stated in the contract, then the contract of sale is valid but
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FIRST DIVISION.
264
264
The Case
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1
This is a
petition for review on certiorari to annul the
2
Decision dated 26 June 1996 of the Court of Appeals in
CAG.R. 3CV No. 41996. The Court of Appeals affirmed the
Decision dated 18 February 1993 rendered by Branch 65 of
the Regional Trial Court of Makati (trial court) in Civil
Case No. 895174. The trial court dismissed the case after
it found that the parties executed the Deeds of Sale for
valid consideration and that the plaintiffs did not have a
cause of action against the defendants.
The Facts
The Court of Appeals summarized the facts of the case as
follows:
Defendant spouses Leonardo Joaquin and Feliciana Landrito are
the parents of plaintiffs Consolacion, Nora, Emma and Natividad
as well as of defendants Fidel, Tomas, Artemio, Clarita, Felicitas,
Fe, and Gavino, all
_______________
1
2
265
265
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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
4
legal basis. (Emphasis in the original)
Ibid., p. 189.
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267
267
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268
268
point is the ruling of the Supreme Court in Velarde, et al. vs. Paez,
et al., 101 SCRA 376, thus:
The plaintiffs are not parties to the alleged deed of sale and are not
principally or subsidiarily bound thereby hence, they have no legal
capacity to challenge their validity.
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11
Article 1078 of the Civil Code of the Philippines states: Where there
are two or more heirs, the whole estate of the decedent is, before its
partition, owned in common by such heirs, subject to the payment of debts
of the deceased.
12
270
xxx
In actions for the annulment of contracts, such as this action,
the real parties are those who are parties to the agreement or are
bound either principally or subsidiarily or are prejudiced in their
rights with respect to one of the contracting parties and can show
the detriment which would positively result to them from the
contract even though they did not intervene in it (Ibaez v.
Hongkong & Shanghai Bank, 22 Phil. 572 [1912]) x x x.
These are parties with a present substantial interest, as
distinguished from a mere expectancy or future, contingent,
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See Ladanga, et al. v. Court of Appeals, et al., 216 Phil. 332 131
17
See Embrado v. Court of Appeals, G.R. No. 51457, 27 June 1994, 233
SCRA 335 TSN, 17 May 1991, 497498 (Emma Joaquin Valdoz) TSN, 22
May 1991, pp. 1112, 2021 (Nora Joaquin Edra).
18
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272
272
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lay hold of the situation and remedy it. (Emphasis in the original)
273
with the factual findings of the trial court. This Court will
not weigh the evidence all over again unless there has been
a showing that the findings of the lower court are totally
devoid of support or are clearly 20erroneous so as to
constitute serious abuse of discretion. In the instant case,
the trial court found that the lots were sold for a valid
consideration, and that the defendant children actually
paid the purchase price stipulated in their respective Deeds
of Sale. Actual payment of the purchase price by the buyer
to the seller is a factual finding that is now conclusive upon
us.
WHEREFORE, we AFFIRM the decision of the Court of
Appeals in toto.
SO ORDERED.
Davide, Jr. (C.J., Chairman), Panganiban, Ynares
Santiago and Azcuna, JJ., concur.
Judgment affirmed in toto.
Note.A contract of sale is perfected at the moment
there is a meeting of minds upon the thing which is the
object of the contract and upon the price. (Delos Reyes vs.
Court of Appeals, 313 SCRA 632 [1999])
o0o
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