## Facts

- In 1942 in Piraeus, Greece (during wartime scarcity), George Batsakis provided Eugenia The. Demotsis 500,000 Greek drachmae, then worth about $25.
- Demotsis signed a written instrument stating she had received a $2,000 U.S. loan for family support and promising to repay $2,000 in U.S. currency.
- The instrument also promised 8% annual interest from April 2, 1942, payable with the principal, at the end of the war or earlier.
- Batsakis later sued Demotsis in Texas to recover $2,000 plus the contractual interest.
- Demotsis asserted want and failure of consideration as to $1,975 and tendered $25 (plus interest) as the value received.
- After a bench trial, the trial court ruled for Batsakis but awarded only $750 in principal (plus 8% interest from April 2, 1942).
- Batsakis appealed, seeking the full $2,000 plus interest; Demotsis did not cross-appeal.

## Issues

1. Whether a written promise to repay $2,000 plus interest is unenforceable because the consideration received was grossly inadequate in value.
2. Whether, absent proof of a vitiating defense (e.g., fraud or duress), a court may reduce the contractual recovery based solely on inadequacy of consideration.

## Decision

- The appellate court modified the judgment to award Batsakis the full $2,000 promised, plus 8% interest from April 2, 1942.
- The court held the contract was supported by consideration because Demotsis received what was bargained for (500,000 drachmae), even if the exchange was economically uneven.
- The court rejected the defense theory that consideration partially failed merely because the drachmae were worth far less than the dollar amount stated in the instrument.
- As modified, the judgment was affirmed.

## Legal Principles

- Mere inadequacy of consideration, without a separate invalidating doctrine, does not render a contract unenforceable.
- Consideration doctrine generally requires a bargained-for exchange, not equivalence in economic value.
- Where consideration exists and the promisor received the agreed performance, a court will not reprice the bargain by reducing the promised payment solely due to disparity in value.

## Conclusion

The court enforced the written promise for $2,000 plus contractual interest despite the drachmae’s low market value, holding that inadequacy of consideration alone is not a basis to void or rewrite an otherwise supported contract.


Batsakis v. Demotsis, 226 S.W.2d 673 (Tex. Civ. App. 1949)