Julian Francisco (Substituted… · G.R. 139982

Petitioner: Julian Francisco (Substituted By His Heirs
Respondent: Pastor Herrera
Citation: G.R. No. 139982
Court: Supreme Court
Division: Second Division
Ponente: Quisumbing, J.
Decided: November 21, 2002

Summary

This case involved the validity of land sale contracts where the seller suffered from senile dementia. Eligio Herrera Sr. sold two parcels of land to Julian Francisco for P1,750,000 in 1991. His son Pastor Herrera challenged the sales, claiming his father was mentally incapacitated due to senile dementia. The RTC and CA declared the contracts null and void. However, the Supreme Court reversed, ruling that contracts by mentally incapacitated persons are merely voidable, not void per se, under Civil Code Article 1390. The Court found that respondent's acceptance of payments and negotiations for price increase constituted implied ratification, validating the contracts. The decision clarifies the important distinction between void and voidable contracts and the legal effects of ratification in cases involving mental incapacity.

Statutes applied

Civil Code, Art. 1390

Related cases

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Spouses Heinzrich Theis v. Honorable Court of Appeals G.R. No. 126013
Marcelino S. Andrino v. Top Services G.R. No. 237028
Miguel Katipunan v. Braulio Katipunan, Jr. G.R. No. 132415
Guiang v. Court of Appeals G.R. No. 125172
The Roman Catholic Church v. Regino Pante G.R. No. 174118

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By the Intellegal Editorial Board · November 21, 2002

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