As opposed to a disposition inter vivos by lucrative or gratuitous title, a valid sale for valuable consideration does not diminish the estate of the seller.

MILAGROS MANONGSONG, etc., et. al. vs. FELOMENA JUMAQUIO ESTIMO, et. al., G. R. No. 136773, June 25, 2003

“x x x.

We likewise find no basis for the trial courts declaration that the sale embodied in the Kasulatan deprived the compulsory heirs of Guevarra of their legitimes. As opposed to a disposition inter vivos by lucrative or gratuitous title, a valid sale for valuable consideration does not diminish the estate of the seller. When the disposition is for valuable consideration, there is no diminution of the estate but merely a substitution of values,^[30] that is, the property sold is replaced by the equivalent monetary consideration.

Under Article 1458 of the Civil Code, the elements of a valid contract of sale are: (1) consent or meeting of the minds; (2) determinate subject matter and (3) price certain in money or its equivalent.^[31] The presence of these elements is apparent on the face of the Kasulatan itself. The Property was sold in 1957 for P250.00.[32

x x x.”]