[Mendoza, Urika Loi M.

Restriction on Civil Capacity: Minority

SUAN CHIAN v. ALCANTARA

March 4, 1950 G.R. No. L-1720 Paras, J.

Relevant Provisions/Concepts/Doctrines

Doctrine: As ruled in Mercado v. Espiritu, the “sale of real estate, made by minors who pretend to be of
legal age, when in fact they are not, is valid…”

FACTS

On August 3, 1931, Rufino Alcantara, and his sons Damaso and Ramon, executed a deed of sale,
conveying five parcels of land to Sia Suan. Ramon was then still a minor (17 years, 10 months, 22 days).
A few days later, Ramon’s lawyer informed Suan’s husband, Gaw Chiao, that Ramon was a minor and
was disavowing the contract. Chiao then contacted Ramon, who then executed an affidavit ratifying the
deed of Sale. Later, Suan sold the lots to Nicolas Azores.

In 1940, Ramon filed a case in the CFI in Laguna for the annulment of the deed of sale of his undivided
share in the two parcels of land in Laguna. The CFI favored Suan et. al., so Ramon appealed to the CA.
The CA reversed the decision on the ground that the deed of sale is not binding to Ramon since he was a
minor on the date of execution. Suan and Chiao appealed to the SC.

ISSUE

Was the deed of sale signed by Ramon Alcantara when he was a minor rendered valid?

RULING

YES. The Court held that Ramon’s previous misrepresentation had already estopped him from disavowing
the contract. It is undeniable that the deed of sale signed by Ramon on Aug. 3, 1931, showed that he, like
his co-signers (father and brother), was then of legal age. Following the doctrine laid down in Mercado v.
Espiritu, the deed of sale signed by Ramon, who misrepresented himself to be of legal age, is valid and
with binding effect.

Contrary to the opinion of CA, the SC ruled that the Mercado v. Espiritu doctrine applies to this case
because as long as the contract is supported by a valid consideration (in this case, the consideration is the
pre-existing indebtedness of Ramon’s father, Rufino), the contract binds a minor who represents himself to
be of legal age.