Policarpio Cayabyab v. The Honorable Intermediate Appellate Court

Summary

This case involves the validity of deeds of sale executed by illiterate elderly spouses Faustino Landingin and Agapita Ferrer in favor of petitioner Policarpio Cayabyab. The respondent heirs challenged the sales alleging fraud, undue influence and abuse of confidence. The trial court initially dismissed the complaint, but the Court of Appeals reversed, finding the sales invalid. The Supreme Court affirmed, applying Article 1332 of the Civil Code which shifts the burden to the party enforcing a contract involving illiterate parties to prove the terms were fully explained. The Court found petitioner failed to meet this burden, noting suspicious circumstances including the vendors' advanced age, language barriers, absence of family members during execution, and lack of credible evidence that consideration was paid. The decision emphasizes judicial protection of disadvantaged parties in contractual relations.