- Petitioner
- Restituta Leonardo
- Respondent
- Court of Appeals
- Citation
- G.R. No. 125485
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Corona, J.
- Decided
- September 13, 2004
Summary
Restituta Leonardo, legitimate daughter of Tomasina Paul, challenged an extrajudicial settlement of estate that gave her only 7,671.75 square meters instead of her proper legitime of 19,282.5 square meters. The Supreme Court found her consent was vitiated by substantial mistake under Article 1332 of the Civil Code, which protects parties unable to read when mistake or fraud is alleged. Private respondents failed to prove the English document was explained to petitioner in her known Pangasinan dialect. Despite her limited education (Grade 3), she was deceived by assurances that her legitimate share was protected. The Court annulled the settlement, emphasizing that the burden shifts to the enforcing party to show terms were fully explained to an illiterate party. The decision reinforced protection for disadvantaged parties in contract formation and distinguished between annulment of voidable contracts versus declaration of nullity of void contracts.