Rañeses v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: The case originated from two civil actions filed by spouses Vicente Rañeses and Zenaida Buena against Antonino Lamadrid. Civil Case No. 2113 involved a parcel of land (TCT No. T-5616) where Lamadrid allegedly intruded into a 6-hectare portion. Lamadrid claimed ownership, alleging the Rañeses' title was void due to fraud. Civil Case No. 2313 concerned another agricultural land (TCT No. T-6098) where Lamadrid allegedly intruded into a 2.5-hectare portion. Lamadrid asserted that the sale to Zenaida Buena was preceded by a sale to Francisco Lumbis, whose rights he acquired, and that the Rañeses' deed was a forgery obtained by fraud. Procedural History: The cases were tried jointly. The trial court ruled in favor of the Rañeses in both cases, declaring Vicente Rañeses the owner in Civil Case No. 2113 and Zenaida Buena the owner of the disputed portion in Civil Case No. 2313, ordering Lamadrid to vacate. Lamadrid appealed to the Intermediate Appellate Court (IAC), but only concerning Civil Case No. 2313, as he did not question the decision in Civil Case No. 2113. The IAC reversed the trial court's decision in Civil Case No. 2313, dismissing the complaint and ordering the Rañeses to pay Lamadrid attorney's fees and costs. The IAC found the Rañeses to be vendees in bad faith and their deed of sale a forgery. The Rañeses' motion for reconsideration was denied. Hence, the present appeal. The Petition: The Rañeses imputed reversible error to the IAC for failing to apply the doctrine of laches, not finding their deed of sale genuine, and not concluding that fraud could not be attributed to them.
Issue(s)
1. Whether or not the Intermediate Appellate Court erred in failing to apply the equitable doctrine of laches to bar Lamadrid from enforcing his claim over the property in question. 2. Whether or not the Intermediate Appellate Court erred in not finding that the evidence demonstrates the correctness of the Trial Court's judgment that the deed of sale (Exhibit 'E') allegedly executed by the Cuevas Spouses in favor of the Rañeses was genuine. 3. Whether or not the Intermediate Appellate Court erred in declining to conclude that, given the facts, fraud cannot be attributed to petitioner or her husband in the execution of Exhibit "E" or in registering the same.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, dismissing the petition and upholding the ruling that the deed of sale in favor of the Rañeses was a forgery and that they were vendees in bad faith. The Court held that the doctrine of laches cannot be invoked to shield fraud or wrongdoing and that the issue of laches was not timely raised.
Ratio Decidendi
On Issue 1: The Supreme Court held that the assertion of laches is foreclosed to the Rañeses due to the Appellate Court's finding that the deed of sale (Exhibit 'E') on which the spouses based their claim was a forgery, procured or participated in by them. This finding of fact is binding on the Supreme Court. The equitable doctrine of laches is designed to promote justice and is not available to shield fraud or wrongdoing. Furthermore, the Court was disinclined to apply laches to prejudice the right of the original transferee, Lumbis, who was found to be an ignorant mine worker, and by extension, his successor-in-interest, respondent Lamadrid. Additionally, the Rañeses raised the issue of laches for the first time only after the rendition of the IAC's decision and in their motion for reconsideration, which amounts to a waiver of such defense as it was not averred in the proceedings before the Trial Court. On Issue 2: The Supreme Court reiterated the general rule that the review of factual conclusions of the Appellate Court and their evidentiary bases is not proper in appeals to the Supreme Court, which should be confined to issues of law. While exceptions exist, such as when there is a conflict in factual findings between the Court of Appeals and the Trial Court (which was present in this case), the Supreme Court's review of the evidence yielded nothing favorable to the petitioners' cause. The IAC's determination that the Rañeses' deed of sale was a forgery, supported by expert testimony and suspicious circumstances (e.g., acknowledgement in a different municipality than where it was executed, and a six-year delay in registration), stands. The Court found no ground to reverse or modify these factual findings. On Issue 3: The Supreme Court affirmed the Appellate Court's finding that the Rañeses were vendees in bad faith. Evidence preponderantly established that Vicente Rañeses knew of the acquisition and occupation of the disputed 2/5 portion by Lumbis (Lamadrid's predecessor) from Isabelo Cuevas, and even knew of Lumbis's subdivision survey. Rañeses' encargado even prepared the deed of sale from Lumbis to Lamadrid. This knowledge, prior to the alleged sale from Cuevas to Rañeses, definitively demonstrates bad faith, as Rañeses knew Cuevas no longer had title to convey. The principle that a forged deed is an absolute nullity and conveys no title clearly militates against according any primacy to the claim of the Rañeses, whose instrument was found to be fraudulent, over that of respondent Lamadrid, whose acquisition was not shown to be similarly defective.
Main Doctrine
In cases of double sales of immovable property, ownership shall belong to the person who in good faith first recorded the sale in the Registry of Property. If there is no inscription, ownership pertains to the person who in good faith was first in possession, and in the absence thereof, to the person who presents the oldest title, provided there is good faith. A forged deed is an absolute nullity and conveys no title.