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RONGAVILLA V. CA G.R. NO.

83974
December 21, 2011
FACTS:
The Dela Cruz sisters were the aunts of Dolores Rongavilla. They borrowed P2,000 from the
Rongavillas to have their rooftop repaired. Later, petitioners went back to their aunts to have
them sign a contract. Taking advantage of their lack of education, the sisters were made to
believe that such document, typewritten in English, was just for the acknowledgment of their
debt. After four years, petitioners asked their aunts to vacate the land subject to litigation
claiming that she and her husband were the new owners. After verifying with the Registry of
Deeds, the aunts were surprised that what they have signed was actually a deed of sale. Their
land title was cancelled and the ownership was transferred to their nephews. The land was
mortgaged with the Cavite Development Bank.
ISSUE:
Does the contract have the right to reform the contract?
HELD:
No. The contract should not be reformed because if mistake, fraud, inequitable conduct, or
accident has prevented a meeting of minds of the parties, the proper remedy is not reformation of
the instrument but annulment of the contract (Art. 1359, Par. 2,Civil Code of the Philippines).
Since Dela Cruz sisters committed fraud who have prepared the contract and believing to their
aunt that it was a contract of loan but in reality it was a deed of sale, the proper remedy is
annulment in the reason that there is no meeting of minds due to vitiated consent.

ELCANO VS HILL - 77 SCRA 100


May 26, 1977
FACTS:
Reginald Hill, a minor, caused the death of Agapito (son of Elcano). Elcano filed a criminal case
against Reginald but Reginald was acquitted for lack of intent coupled with mistake. Elcano then
filed a civil action against Reginald and his dad (Marvin Hill) for damages based on Article 2180 of
the Civil Code. Hill argued that the civil action is barred by his sons acquittal in the criminal case;
and that if ever, his civil liability as a parent has been extinguished by the fact that his son is already
an emancipated minor by reason of his marriage.

ISSUE:
Is the father of a minor held civilly liable?
HELD:
Art. 101 of the Revised Penal Code prescribes the subsidiarily liability of the parents in case of a
minor over 9 but under 15 who DID NOT act with discernment. If he acted WITH discernment,
Revised Penal Code is silent because he is criminally liable. In that case, resort is made to the
general law which is the Civil Code, Ary. 2080 of which applies. Under said Article, the parents
would be held liable unless they can prove due supervision. To hold that the Civil Code does not
apply because it covers only obligations arising from negligence or quasi-delicts would result in
an ABSURDITY for, while in a negligent act, the parents are liable for the damage caused by his
son, no liability would attach if the damage is caused with criminal intent. It is clear, therefore,
that applying Art. 2080 of the Civil Code, the parents would ordinarily be liable.
While it is true that parental authority is terminated upon emancipation of the child (Article 327,
Civil Code), and under Article 397, emancipation takes place by the marriage of the minor
child, it is, however, also clear that pursuant to Article 399, emancipation by marriage of the
minor is not really full or absolute. Thus Emancipation by marriage or by voluntary concession
shall terminate parental authority over the childs person. It shall enable the minor to administer

his property as though he were of age, but he cannot borrow money or alienate or encumber real
property without the consent of his father or mother, or guardian. He can sue and be sued in court
only with the assistance of his father, mother or guardian. Therefore, Article 2180 is applicable
to Marvin Hill the SC however ruled since at the time of the decision, Reginald is already of
age, Marvins liability should be subsidiary only as a matter of equity.

LIM VS COURT OF
APPEALS AND DY - G.R. NO. 87047
October 31, 1990
FACTS:
Records show that Francisco Lim, entered into a contract of lease with Benito Dy for a period of
3 years, from 1976 to 1979. After the stipulated term expired the respondent refused to leave the
premises, so Francisco Lim filed an ejectment suit against Benito Dy. This case was then taken
over by a judicially approved compromise agreement which provides an automatic increase in
rent of 20% every 3 years. On 1985 Dy, informed Lim of his intention to renew the lease up to
1988, Lim did not agree to the renewal.
In 1987 another ejectment suit was filed by Lim after the failure of Dy to vacate the premises. It
was dismissed by the RTC and later affirmed by the CA for the following reasons: (1) the
stipulation in the compromise agreement which allows the lessee (Benito Dy) to stay on the
premises as long as he needs it and can pay rents is valid, being a resolutory condition, and
therefore beyond the ambit of art 1308 of the NCC; and (2) the compromise agreement has the
effect of res judicata.
ISSUE:
Was the stipulation in the compromise agreement which allows the lessee to stay on the premises
as long as he needs it and can pay rents is valid?
HELD:
No, since the stipulation for as long as the defendant needed the premises and can meet and pay
said increases is a purely potestative condition because it leaves the effectivity and enjoyment
of leasehold rights to the sole and exclusive will of the lessee. This can be found in Art 1182 of

the New Civil Code of the Philippines, when the fulfillment of the condition depends upon the
sole will of the debtor, the conditional obligation shall be void.

KATIPUNAN VS. KATIPUNAN, JR.


- 3537 SCRA 199.
January 30, 2002
FACTS:
Respondent Braulio Katipunan Jr. is the registered owner of a lot and a five-door apartment
constructed thereon, which were occupied by lessees. Respondent assisted by his brother
petitioner Miguel entered into a Deed of Absolute Sale with brothers Edardo Balguma and
Leopoldo Balguma, Jr. ( co-petitioners), represented by their lawyer-father involving the subject
property for a consideration of P187,000.00. So, the title was registered in the names of the
Balguma

brothers

and

they

started

collecting

rentals

thereon.

Later, Braulio filed a complaint for annulment of the Deed of Absolute Sale, contending that his
brother Miguel, Atty. Balguma and Inocencio Valdez (one of the petitioners) convinced him to
work abroad. Through insidious words and machinations, they made him sign a document
purportedly a contract of employment, which document turned out to be a Deed of Absolute
Sale. He further alleged that he did not receive the consideration stated in the contract. He
claimed that there was evident bad faith and conspiracy in taking advantage of his ignorance, he
being

only

third

grader.

The RTC dismissed the complaint because Braulio failed to prove his cause of action since he
admitted that he obtained loans from the Balgumas, he signed the Deed of Absolute Sale, and he
acknowledged selling the property and stopped collecting the rentals. But when the case was
elevated, the decision of RTC was reversed and it was held that Braulio was incompetent, has
very low I.Q., illiterate and has a slow comprehension. The CA based its decision on Arts.1332
and 1390 of NCC and Sec. 2, Rule 92 of the Rules of Court, concerning the incompetence of a
party in contract.
ISSUE:

Was there a valid contract of sale between the parties?


HELD:
No. There was a vitiated consent on the part of the respondent as he signed the Deed of Absolute
Sale without the remotest idea of what it was and received no consideration thereof. A contract
of sale is born from the moment there is a meeting of minds upon the thing which is the object of
the contract and upon the price. For the contract to be valid, the following requisites must be
followed: (1) the consent of the contracting parties; (2) the object certain which is the subject
matter of the contract; (3) the cause of the obligation which is established. The contract entered
into by the parties being voidable contract, was correctly annulled on appeal. Under Art. 1330 of
NCC, a contract where consent is given through mistake, violence, intimidation, undue influence,
or fraud is voidable. Also, under Art. 1398 of NCC, an obligation having been annulled, the
contracting shall restore to each other the things which have been the subject matter of the
contract, with their fruits, and the price with its interest, except in cases provided by law. Thus,
since the contract of sale between respondent and Balguma brothers is voidable and hereby
annulled, then the restitution of the property and its fruits to respondent is just and proper.

JLT AGRO V. BALASAG


453 SCRA 211
FACTS:
Don Julian had two marriages during his lifetime. During his first one, with Antonia, he had two
children. In the second marriage, he had 4 children with Milagros. Upon the death of Antonia,
the first children sought the partition of the property. On the disputed Lot 63, there was a
compromise agreement entered into by the parties whereby Lot 63 was supposed to be
exclusively adjudicated in favor of his second wife and children by the same.
ISSUE:
Is the partition inter vivos valid?
HELD:
Yes. The partition inter vivos of Don Julian is valid. Under Art. 1080, should a person make a
partition of his estate by an act inter vivos, or by will, such partition shall be respected, insofar as
it does not prejudice the legitime of the compulsory heirs. However, the partition will of course
be effective only after his death only. The right of his heirs from the second marriage would
become legally operative only upon the death of Don Julianall is just a mere expectancy.
Evidently, at the time of execution of deed of assignment, Julian remained the owner of the
properties.