Gevero v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: The underlying dispute concerns ownership of a parcel of land, specifically Lot No. 2476-D of the Cagayan Cadastre, with an area of 7,878 square meters. Del Monte Development Corporation (DELCOR) claims ownership based on a purchase from Luis Lancero, who had acquired the land from Ricardo Gevero. The petitioners, heirs of Ricardo Gevero, contest the validity of the sale and assert their right to the property, which they claim was part of the estate of their mother, Teodorica Babangha. Procedural History: DELCOR filed an action with the Court of First Instance (now Regional Trial Court) of Misamis Oriental to quiet title and/or annul the extra-judicial partition made by the heirs of Teodorica Babangha, alleging that it prejudiced the land DELCOR had acquired. The trial court ruled in favor of DELCOR, declaring it the absolute owner of Lot No. 2476-D and adjudicating other portions of Lot No. 2476 to various parties. The petitioners, heirs of Ricardo Gevero, appealed this decision to the Intermediate Appellate Court (IAC), which affirmed the trial court's ruling. A subsequent motion for reconsideration filed by the petitioners was denied. The Petition: The petitioners seek review on certiorari of the IAC's decision, raising several arguments. They contend that the deed of sale from Ricardo Gevero to Luis Lancero is invalid due to alleged forgery of Ricardo's signature, lack of consideration, and discrepancies in lot numbers and area. They also argue that Lancero's subsequent actions indicated recognition of the deed's defects, that Ricardo's children remained in possession, and that the sale did not include Ricardo's inherited share from his mother, Teodorica Babangha. Furthermore, they claim DELCOR's action is barred by laches due to their continued possession of the property. The petitioners argue that the deed of sale was flawed and that the subsequent partition and registration were improper.
Issue(s)
Whether the deed of sale executed by Ricardo Gevero to Luis Lancero is valid. Whether the 1/2 share of interest of Teodorica Babangha in Lot 2476 is included in the deed of sale. Whether the private respondent's (DELCOR) action is barred by laches.
Ruling
The Supreme Court dismissed the petition and affirmed the decision of the Court of Appeals, upholding DELCOR's ownership of Lot No. 2476-D.
Ratio Decidendi
On the validity of the deed of sale: The Court held that the 1952 deed of sale, being a public document duly acknowledged before a notary public, enjoys the presumption of regularity. The petitioners failed to present clear and convincing evidence to rebut this presumption and prove forgery. The allegation of absence of consideration was also unsubstantiated, as consideration is presumed under Article 1354 of the Civil Code. Furthermore, any alleged admission by Luis Lancero in a 1968 document titled "Settlement to Avoid Litigation" was deemed inadmissible against DELCOR, as Lancero's ownership had already passed to DELCOR in 1964, invoking the principle of res inter alios acta. The claim of continued possession by the petitioners was a question of fact already resolved by the lower courts and binding on the Supreme Court. Other alleged flaws in the deed were not raised before the trial or appellate courts and thus could not be raised for the first time on appeal. On the inclusion of Teodorica Babangha's share: The Court clarified that the hereditary share in an estate is transmitted from the moment of the predecessor's death. Since Teodorica Babangha died long before World War II, Ricardo Gevero's inheritance vested immediately. Therefore, when Ricardo sold his share in Lot 2476, his inherited share from Teodorica was also included in the sale, unless expressly excluded. The petitioners' interpretation of a specific paragraph in the deed, excluding Teodorica's share, was rejected as it would create contradictions and render other provisions meaningless. The Court emphasized that laws and contracts must be construed to harmonize and give effect to all their provisions, and the entirety of the contract must be taken into account. On whether DELCOR's action is barred by laches: The Court ruled that DELCOR's action is not barred by laches. The execution of a public instrument, like the deed of sale, is equivalent to the delivery of the property under Article 1498 of the Civil Code. Moreover, the property involved is registered land, and ownership transfers upon registration. A purchaser in good faith of registered land has the right to rely on the certificate of title and is under no duty to go behind it. The Court noted that DELCOR went beyond merely relying on the title; it investigated Lancero's title, the subdivision plan, technical description, and the deed of sale, and confirmed Lancero's possession. These actions demonstrated DELCOR's good faith in purchasing the land.
Main Doctrine
A notarized deed of sale enjoys the presumption of regularity and requires clear and convincing evidence to prove forgery. A purchaser in good faith of registered land may rely on the certificate of title and is not obligated to investigate beyond it.