- Petitioner
- Andrea Mayor
- Respondent
- Lourdes Masangkay Belen
- Citation
- G.R. No. 151035
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ynares-Santiago, J.
- Decided
- June 3, 2004
Summary
This case involves the validity of two contracts - a deed of absolute sale (Kasulatan ng Bilihang Tuluyan) and a real estate mortgage (Kasulatan ng Sanglaan) - executed between the same parties regarding a 179 square meter residential lot in San Pablo City. Respondent Lourdes Belen, who had limited education, alleged that petitioners Andrea Mayor and Vergel Romulo fraudulently induced her to execute these contracts by falsely representing that her original purchase was void and she might lose her payments. The Supreme Court applied Article 1332 of the Civil Code, which shifts the burden of proof to the party seeking to enforce a contract when the other party is unable to read or understand the contract language. Finding that petitioners failed to prove the contracts were properly explained to Lourdes, the Court upheld the lower courts' ruling declaring the contracts null and void due to fraud. The decision emphasizes the protection of parties with limited education in contract formation and the rebuttable nature of the presumption of regularity in notarized documents.