BARANDA V.

BARANDA

MAY 20, 1987

CRUZ, J.

Facts:
 Decedent Paulina Baranda died without issue and without a will. Her collaterals were wrangling over
her properties and even before her death, two of the claimants had already taken over her properties.
 The questioned sales were effected through three deeds denominated as “Bilihan ng Lupa” executed
by her nieces Evangelina and Elisa Baranda. The sales were made for a total consideration of
P105,000.00
 Paulina subsequently filed a complaint against the two, alleging that she signed the said deeds of sale
without knowing what the contents were and prayed for the reconveyance of the lands. This
complaint was later withdrawn pursuant to an agreement between the parties where Evangelina and
Elisa obligated themselves to execute absolute deeds of sale in favor of Paulina. However, only Elisa
complied.
 Paulina died and the certificate of title over the lots were still in the name of the nieces. Hence,
petitioners, claiming to be the legitimate heris of Paulina, filed a complaint against Evangelina and
Elisa for the annulment of the sale and reconveyance of the lots with damages.
 RTC ruled in favor of petitioners, declaring the deeds of sale null and void. However, IAC reversed,
upholding their validity, stressing that they were public documents and their authenticity were
sustained by respondents’ testimonies.
 Hence, this petition.

Issues:
WON the deed of sale is valid. NO.
[main] WON the petitioners have the capacity as proper parties to sue respondents. YES.
WON action has prescribed. NO.

Ratio:
As to the validity of the deed of sale
 The Court considered the following facts in arriving at the conclusion that there was no valid
consideration:
o According to Evangelina, the sum of P100,000.00 was given to her by her “balikbayan”
boyfriend. As for Elisa, she said Evangelina lent her P15,000.00 and raised another
P15,000.00 from her grandmother in the province, by selling the latter’s properties. Court
noted that at the time of the supposed sale, neither Evangelina nor Elisa was gainfully
employed or had independent sources of income, both being then fresh college graduates
aged 25 and 26, respectively.
o Court did not believe in the existence of Evangelina’s imaginary “balikbayan” boyfriend. He
was not even presented at the trial. As for Elisa, she did not even present any document to
prove that her grandmother did sell properties to raise the P15,000.00. Court found it hard
to believe that this old woman would agree to sell her properties in the province where she
was presumably making a living.

As to the capacity of petitioners to sue

 Petitioners have a legal standing and are legitimate intestate heirs of Paulina. Petitioners are siblings
(dead ones are represented by their spouses) of Paulina and children of her two deceased brothers
and a sister. Their claims are not merely contingent or expectant but are deemed to have vested in
them upon Paulina’s death. While they are not compulsory heirs, they are nonetheless legitimate
heirs.
 Art. 1003. If there are no descendants, ascendants, illegitimate children, or a surviving spouse, the
collateral relatives shall succeed…

 Neither can it be argued that petitioners cannot assail the said contracts on the ground that they were
not parties to the contract because as heirs of Paulina, they are affected. Their rights are prejudiced.

As to prescription of the action

 According to Art. 1391, an action to annul a contract on the ground of vitiated consent must be filed
within 4 years from the discovery of the vice of consent. In this case, however, we are not dealing with
just a voidable contract. It is a contract that is null and void ab ignition because she had not given her
consent at all. Paulina declare under oath that she signed the deeds of sale without knowing what
they were. It’s as if she had not given her consent at all.