Raul Santos By v. Heirs of Jose P. Mariano & Erlinda Mariano-Villanueva; & the Law Firm of San Buenaventura

Summary

This case involves a property dispute over six parcels of land originally owned by spouses Macario and Irene Mariano. After Macario's death, Irene executed deeds of sale in favor of Raul Santos, her second husband's cousin, in 1975 and 1982. However, Irene continued to possess and control the properties until her death in 1988. The adopted children and heirs, Jose and Erlinda, challenged the validity of the sales, claiming they were simulated contracts lacking genuine consent. The NBI found irregularities in the documents. While the trial court initially upheld the sales citing a previous Supreme Court ruling, the Court of Appeals granted a new trial based on newly discovered evidence and ultimately declared the deeds null and void for lack of meeting of minds. The Supreme Court affirmed, emphasizing that valid contracts require the essential elements of consent, object, and cause under the Civil Code, and that due execution of documents does not automatically establish contract perfection.