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Case Digest on Obligations and Contracts: Capacity to Contract - Dr. Jose and Aida Yason vs. Faustino Arciaga, et al. G.R. No. 145017

Dr. Jose and Aida Yason vs. Faustino Arciaga, et al.
G.R. No. 145017, January 28, 2005
Facts:
Spouses Arciaga were owners of a parcel of land in Muntinlupa City covered by TCT of the Registry of Deeds of Makati City. On March 28, 1983, they executed a Deed of Conditional Sale whereby they sold the lot to spouses Dr. Jose and Aida Yason, petitioners. On April 19, 1983, upon payment of the balance, spouses Arciaga executed a Deed of Absolute Sale. That day,  Claudia Arciaga died.
Later in 1989, respondent’s children filed with the RTC a complaint for annulment of the land titles against the petitioners. Respondents alleged inter alia  that the Deed of Absolute Sale is void ab initio considering that Claudia did not give her consent to the sale as she was then seriously ill, weak and unable to talk.
On October 29, 1995, the trial court rendered a Decision dismissing respondents’ complaint and sustaining the validity of the Deed of Conditional Sale and the Deed of Absolute Sale.
Initially, the CA affirmed the trial court’s ruling but upon respondents’ motion for reconsideration, the CA reconsidered its decision, declaring the Deed of Absolute Sale void. Hence this petition for review on certiorari.
Issue: Whether the Deed of Absolute Sale is void as Claudia was incapacitated to enter a contract due to advanced years and physical infirmities.
Ruling:
The petition is impressed with merit. Challenged CA decision reversed; decision of RTC dismissing respondents’ complaint is affirmed.
A person is not incapacitated to enter into a contract merely because of advanced years or by reason of physical infirmities, unless such age and infirmities impair his mental faculties to the extent that he is unable to properly, intelligently and fairly understand the provisions of said contract.
Respondents failed to show that Claudia was deprived of reason or that her condition hindered her from freely exercising her own will at the time of the execution of the Deed of Conditional Sale.
It is of no moment that Claudia merely affixed her thumbmark on the document. The signature may be made by a person's cross or mark even though he is able to read and write and is valid if the deed is in all other respects a valid one. Significantly, there is no evidence showing that Claudia was forced or coerced in affixing her thumbmark on the Deed of Conditional Sale.

The burden is on the respondents to prove the lack of capacity on the part of Claudia to enter into a contract. And in proving this, they must offer clear and convincing evidence. This they failed to do.
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