Bagnas v CA

176 SCRA 159 (1989)

1st Division – J Narvasa
Topic: adequacy of price
FACTS
- March 11, 1964: Hilario Mateum died single, without ascendants or descendants, and
survived only by petitioners who are his collateral relatives. He left no will, no debts, and an
estate consisting of 29 parcels of land in Kawit and Imus, 10 of which are involved in this
controversy.
- April 3, 1964: respondents who are also collateral relatives – but more distant – of the
deceased, registered 2 deeds of sale purportedly executed by Mateum in their favor. The
considerations were P1.00 and “services rendered, being rendered, and to be rendered for
my benefit”. On the strength of the deeds, respondents were able to secure title over the 10
parcels of land.
- May 22, 1964: petitioners commenced a suit against respondents, seeking annulment of the
deeds of sale a fictitious, fraudulent or falsified or, alternatively, as donations void for want
of acceptance in public instrument. Respondents contend that the sales were made for
valuable considerations, and attacked the legal standing of the petitioners as being mere
collateral heirs.
- TC ruled in favor of respondents, dismissing the suit stating that (a) plaintiffs, as mere
collateral relatives, not forced heirs, of Hilario Mateum, could not legally question the
disposition made by said deceased during his lifetime, & (b) that the plaintiffs evidence of
alleged fraud was insufficient, the fact that the deeds of sale each stated a consideration of
only Pl.00 is not in itself evidence of fraud or simulation.
- CA affirmed TC decision.

ISSUES/HELD/RATIO
1. W/N petitioners have legal standing to sue – if contract is void, then petitioners have
standing.
- If voidable, then petitioners (collateral relatives) have no actionable right to question those
transfers - as Mateum had no forced heirs whose legitimes may have been impaired.
- If void ab initio (because contract has no consideration), then plaintiffs may assail.
- Contracts with false cause aren’t merely voidable, but void. Thus, logical consequence of
that change is the juridical status of contracts without, or with a false, cause is that
conveyances of property affected with such a vice cannot operate to divest and transfer
ownership, even if unimpugned.

2. W/N sale is void or voidable – void.

- It can be seen that there is gross AND enormous disproportion between the stipulated price
(in each deed) of P l.00 plus unspecified and unquantified services, and the indisputably
valuable real estate allegedly sold worth at least P10,500.00 (to add to the fact that this is
merely based on tax assessments which don’t convey the true price). This plainly and
unquestionably demonstrates that they state a false and fictitious consideration, and no
 other true and lawful cause having been shown, the SC finds both deeds not merely
voidable, but void ab initio.
- Neither can the validity of said conveyances be defended on the theory that their
true causa is the liberality of the transferor and they may be considered in reality
donations because the law also prescribes that donations of immovable property, to be
valid, must be made and accepted in a public instrument. In the case, there has been no
such acceptance. The transfers in question being void, it follows as a necessary
consequence and conformably to the concurring opinion in Armentia, with which the Court
fully agrees, that the properties purportedly conveyed remained part of the estate of Hilario
Mateum, said transfers notwithstanding, recoverable by his intestate heirs, the petitioners
herein, whose status as such is not challenged.

JUDGMENT: CA decision REVERSED. Questioned transfers considered void ab initio and

ordered to return to petitioners’ possession.