Pedro Escutin v. Socorro Escutin

Summary

The Supreme Court affirmed the nullification of a deed of sale executed by Sabas Escutin conveying land to Socorro Escutin twelve days before his death. The legitimate children of Sabas challenged the deed as simulated and fraudulent. The Court found that the stated consideration of P1,925 was never actually paid, as neither Socorro nor her mother had any means of income to afford the purchase of land worth P3,750. Witness testimony revealed that Socorro and her mother begged the dying Sabas to convey the land and that no money exchanged hands. Under Article 1275 of the Civil Code, contracts without consideration produce no effect. The Court treated this as a simulated transfer made to defraud the legitimate heirs, following established doctrine that such transfers may be considered non-existent for all purposes.