Short answer. Not on the price alone. Article 1470 provides that gross inadequacy of price does not affect a contract of sale, except as it may indicate a defect in the consent or that the parties really intended a donation or some other act. The low price is evidence, not a ground.
What the law says
Gross inadequacy of price does not affect a contract of sale, except as it may indicate a defect in the consent, or that the parties really intended a donation or some other act or contract.
Civil Code, Article 1470 — Gross Inadequacy of Price. Read the full provision →
A bad bargain is still a bargain
The starting position is that people may sell their property for whatever they are willing to accept. Family members sell to each other cheaply, an owner in a hurry takes less than the zonal value, a seller prefers a quick cash buyer to a better offer that needs financing. None of that is unlawful, and Article 1355 says the same thing from the other direction: except in cases specified by law, lesion or inadequacy of cause shall not invalidate a contract unless there has been fraud, mistake or undue influence. The price is not the ground of attack.
The two doors Article 1470 leaves open
The exceptions matter more than the rule, because a price far below value is precisely how the two problems show themselves. The first is a defect in the consent — the seller did not truly agree, because of intimidation, undue influence, mistake or fraud. The second is that the deed does not say what the parties really did: they intended a donation or some other arrangement and dressed it as a sale. In both cases the low price is the symptom that makes a court look. What is actually being proved is the vitiated consent or the concealed agreement.
Disguised transactions and unpaid prices
Article 1345 recognises that simulation may be absolute, where the parties do not intend to be bound at all, or relative, where they conceal their true agreement. Article 1471 takes the extreme case: if the price is simulated, the sale is void, though the act may be shown to have been in reality a donation or some other contract. Note the difference from a merely low price. A price of one peso that was actually paid is a real if foolish sale; a stated price that never changed hands at all is a different animal, and that distinction is usually decided by bank records rather than argument.
What actually decides these cases
The evidence is about circumstances, not valuation. Who prepared the deed, who chose the notary, whether the seller could read it, the seller's age, illness or dependence on the buyer, whether the money was ever received, and whether the seller went on living on the property and paying its taxes afterwards. Note too that consent-based attacks have their own deadline: under Article 1391 an action for annulment runs four years, from the discovery in cases of fraud or mistake, and from the time the pressure ceased where there was intimidation or undue influence.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Blemp Commercial Philippines, Inc vs. the Hon. Sandiganba Yan, G.R. No. 199031, October 10, 2022 — read the decision on LawPhil →
- Spouses Domingo and Lourdes Paguyo vs. Pierre Astorga, et al, G.R. No. 130982, September 16, 2005 — read the decision on LawPhil →
- Spouses Bernardo Buenaventura, et al. vs. Court of Appeals, et al, G.R. No. 126376, November 20, 2003 — read the decision on LawPhil →
- Hiers of Policronio M. Ureta, Sr., namely: Conrado B. Ureta, et al. vs. Heirs of Liberato M. Ureta, namely: Teresa F. Ureta, et al./Heirs of Liberato M. Ureta, namely: Teresa F. Ureta, et al. vs. Heirs of Policronio M. Ureta, Sr., namely: Conrado B. Ureta, et al, G.R. No. 165748 / G.R. No. 165930, September 14, 2011 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1470 — Gross Inadequacy of Price
- Civil Code, Article 1355 — Lesion or Inadequacy of Cause
- Civil Code, Article 1345 — Simulation of Contracts
- Civil Code, Article 1471 — Simulated Price
- Civil Code, Article 1391 — Four Years to Annul