Digested Sales Cases
Mapalo v. Mapalo
Facts:
Miguel Mapalo and Candida Quiba, simple illiterate farmers, were registered owners of a residential land in Manaoag, Pangasinan. Out of love and affection for Maximo Mapalo, Miguel’s brother who was about to get married, they decided to donate the eastern half of the land. However, they were deceived into signing a deed of absolute sale of the entire land on October 15, 1936. The document showed a consideration of P500, but the spouses actually did not receive anything. The spouses built a fence segregating the donated land. They continued to possess the western part up to the present. Not known to them, on March 15, 1938, Maximo registered the deed of sale in his favor and was able to obtain a TCT. On October 20, 1951, Maximo sold the entire land to the Narcisos, and a TCT was issued. The Narcisos took possession of the eastern part and filed a suit against Miguel and Candida, as well as Floro Guieb and Rosalia Mapalo Guieb who had a house on the western portion consented by the spouses. The spouses filed an answer with counterclaim, seeking cancellation of the TCT of the Narcisos on the ground that their consent to the deed of sale in favor of Maximo was obtained through fraud. The spouses also instituted a complaint to nullify the deeds of sale in 1936 and 1951. The trial court tried the case jointly. It ruled in favor of Miguel and Candida. The appellate court, however, reversed the judgment and rendered the sale valid on the ground of prescription. According to the appellate court, the sale is voidable and subject to annulment only within 4 years after discovery of fraud. It reckoned March 15, 1938, the date of registration, to be the reckoning period.
Issues:
(1) Whether, under the old civil code which was in effect during the execution of the sale, the sale to Maximo is void or merely voidable
(2) Whether the Narcisos were purchasers in good faith
Held:
(1) For a contract to exist at all, three essential requisites must
Facts:
Miguel Mapalo and Candida Quiba, simple illiterate farmers, were registered owners of a residential land in Manaoag, Pangasinan. Out of love and affection for Maximo Mapalo, Miguel’s brother who was about to get married, they decided to donate the eastern half of the land. However, they were deceived into signing a deed of absolute sale of the entire land on October 15, 1936. The document showed a consideration of P500, but the spouses actually did not receive anything. The spouses built a fence segregating the donated land. They continued to possess the western part up to the present. Not known to them, on March 15, 1938, Maximo registered the deed of sale in his favor and was able to obtain a TCT. On October 20, 1951, Maximo sold the entire land to the Narcisos, and a TCT was issued. The Narcisos took possession of the eastern part and filed a suit against Miguel and Candida, as well as Floro Guieb and Rosalia Mapalo Guieb who had a house on the western portion consented by the spouses. The spouses filed an answer with counterclaim, seeking cancellation of the TCT of the Narcisos on the ground that their consent to the deed of sale in favor of Maximo was obtained through fraud. The spouses also instituted a complaint to nullify the deeds of sale in 1936 and 1951. The trial court tried the case jointly. It ruled in favor of Miguel and Candida. The appellate court, however, reversed the judgment and rendered the sale valid on the ground of prescription. According to the appellate court, the sale is voidable and subject to annulment only within 4 years after discovery of fraud. It reckoned March 15, 1938, the date of registration, to be the reckoning period.
Issues:
(1) Whether, under the old civil code which was in effect during the execution of the sale, the sale to Maximo is void or merely voidable
(2) Whether the Narcisos were purchasers in good faith
Held:
(1) For a contract to exist at all, three essential requisites must