Land Sale Nullification Due to Alleged Exploitation Rejected

A property owner sought the nullification of a land sale agreement, arguing the contract was void due to exploitation under Article 21 of the Code of Obligations (OR), as the agreed-upon sale price for a small strip of land, combined with the opposing party's withdrawal of administrative appeals against the planned multi-family housing construction, resulted in a clear disproportion between the contractual performances. The court rejected the claim, reasoning that although the low purchase price indicated an objective discrepancy, the party seeking nullification failed to sufficiently prove they were in a state of necessity or strong financial distress—such as being compelled by significant, imminent financial harm from construction delays—which is required alongside the objective imbalance and subjective exploitation to establish contractual invalidity under Article 21 OR; the mere existence of high financing costs was insufficient to demonstrate the requisite strong economic duress.