Petitioner
Jocelyn B. Doles
Respondent
Ma. Aura Tina Angeles
Citation
G.R. No. 149353
Court
Supreme Court
Division
First Division
Ponente
Austria-Martinez, J.
Decided
June 26, 2006

Summary

This case involves a dispute over the validity of a Deed of Absolute Sale executed by Jocelyn Doles in favor of Ma. Aura Angeles over a property in Bacoor, Cavite, allegedly to satisfy a P405,430.00 debt. The Supreme Court ultimately ruled that the sale was void for lack of consideration, finding that both parties acted merely as agents - Doles for her friends who were the actual borrowers, and Angeles for financier Arsenio Pua. Since the parties were not privy to the loan contract between their principals, the sale predicated on that loan lacked valid consideration. The Court applied the doctrine of estoppel, noting both parties had disclosed they were representing others, and found additional anomalies in the property title that undermined Doles' authority to convey the property. The decision reinforces fundamental Civil Code principles regarding valid consideration in contracts and the nature of agency relationships.

Statutes applied

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By the Intellegal Editorial Board · June 26, 2006

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