Spouses Eugenio de Vera v. Fausta Catungal

Summary

This case involves a dispute over the validity of a Deed of Extrajudicial Settlement Among Heirs with Absolute Sale executed in 1994. Fausta Catungal, an 84-year-old illiterate woman, and her brother Genaro sold their inherited land to spouses Eugenio de Vera and Rosalia Padilla for P30,000. Fausta later sued, claiming the spouses deceived her into believing the document was merely evidence of debt, not a sale. The RTC dismissed the case, but the Court of Appeals reversed, applying Article 1332 of the Civil Code which creates a presumption of fraud when an illiterate party's consent is alleged to be vitiated. The Supreme Court affirmed, finding that Fausta's illiteracy was established and the spouses failed to prove the deed's contents were explained to her. The Court held that Fausta's consent was vitiated by fraud, making the deed voidable, and ordered restoration of the properties to both Fausta's and Genaro's heirs. This case demonstrates the Civil Code's protection for illiterate parties in contract formation and the burden on the enforcing party to prove adequate explanation of terms.