Buenaventura vs.

CA (2003) FACTS: Defendant spouses Leonardo Joaquin and Feliciana Landrito are parents of codefendants Fidel, Tomas, Artemio, Clarita, Felicitas, Fe, and Gavino. They are also the parents of plaintiffs Consolacion, Nora, Emma, and Natividad. A deed of sale was executed by the defendant spouses in favor of their co-defendant children. However, such deed of sale was sought to be declared null and void by the plaintiffs. Plaintiffs argue that: 1. There was no actual consideration 2. Even assuming there was consideration, the properties are more than 3fold times more valuable than the measly sums appearing therein. 3. The sale was the result of a deliberate conspiracy to unjustly deprive the rest of the compulsory heirs of their legitime. RTC: ruled in favor of the defendants and dismissed the complaint. On the grounds that: 1. Plaintiffs do not have a valid cause of action against defendants since there can be no legitime to speak of prior to the death of their parents. 2. Legitime is computed as of the time of the death of the decedent. CA: affirmed the decision of the RTC ISSUE: I. W/N the Deeds of Sale are void for lack of consideration HELD: I. DEED OF SALE VALID. 1. A contract of sale is not a real contract, but a consensual contract. 2. As a consensual contract, a contract of sale becomes a binding and valid contract upon the meeting of the minds as to price. 3. 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. 4. It is not the act of payment of price that determines the validity of a contract of sale. 5. Payment of the price has nothing to do with the perfection of the contract. 6. Failure to pay the consideration is different from lack of consideration. 7. Petitioners do not have any legal interest over the properties. Their rights over the properties are merely inchoate and vests only upon their parents death.