Maria Acosta Francisco v. Antonio Y. Montes

Summary

The Supreme Court affirmed the Court of Appeals' dismissal of petitioners' action to annul a mortgage contract and foreclosure proceedings. The petitioners challenged the validity of a 2002 mortgage deed claiming that Janet Acosta Francisco was a minor when she signed it. The Court applied the doctrine of estoppel, ruling that having benefited from the loan, petitioners could not later challenge the contract's validity. While Janet's minority rendered the contract voidable as to her share under Civil Code Articles 1327 and 1390, her failure to seek annulment within the four-year prescriptive period under Article 1391 constituted ratification. The Court emphasized that despite defective notarization, the parties' actual execution and benefit from the contract, coupled with their admission of indebtedness, validated the mortgage agreement.