Spouses Surban v. Court of Appeals
REITERATIONFacts
The Antecedents: This case concerns a property dispute originating from the sale of a lot and house in Makati. Amador Surban initially purchased the property in November 1977. His children, Rogelio Surban and Leticia Surban-Perello, contributed financially to this purchase. Rogelio Surban and his wife, Erlinda, later emigrated to Guam. Amador Surban and his wife, Severa, also moved to Guam. While Amador and Severa were in Guam, the property in Makati was occupied by Leticia Surban-Perello and her husband, Frisco Perello. Subsequently, Amador and Severa Surban sold the Makati property to their son Rogelio and his wife Erlinda. Procedural History: In 1979, Amador and Severa Surban sold their Makati property to Rogelio and Erlinda Surban, who subsequently registered the sale and obtained a transfer certificate of title in their names. In 1984, after Leticia Surban-Perello expressed interest in purchasing the property and was informed of Rogelio's intention to sell it to others, she, along with her husband Frisco Perello and parents Amador and Severa Surban, filed a complaint against Rogelio and Erlinda Surban for Quieting of Title and Damages. The Regional Trial Court of Makati dismissed this complaint. The Perellos appealed this decision to the Court of Appeals, which affirmed the lower court's decision in its entirety. The Petition: The petitioners, Spouses Amador B. Surban and Severa S. Surban, and Spouses Frisco Perello and Leticia S. Perello, seek review of the Court of Appeals' decision through a petition for certiorari under Rule 45 of the Rules of Court. They raise issues concerning the American citizenship of Rogelio and Erlinda Surban at the time of the property acquisition and the validity of the deed of sale. The petitioners argue that their parents were allegedly tricked into signing the deed of sale and that Rogelio and Erlinda may have lost their Filipino citizenship. The Supreme Court's review is limited to errors of law, as findings of fact by lower courts are generally conclusive.
Issue(s)
Whether the Supreme Court can review factual issues regarding the alleged misrepresentation in the Deed of Sale. Whether the Deed of Absolute Sale is valid, considering the alleged misrepresentation and the citizenship of the buyers. Whether the issue of citizenship can be raised as a collateral issue in a complaint for Quieting of Title.
Ruling
The petition is dismissed for lack of merit. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the review of factual issues: The Supreme Court reiterated that its jurisdiction under Rule 45 of the Rules of Court is limited to reviewing errors of law, and its findings of fact are conclusive. The petitioners' contention that Rogelio Surban tricked their parents into signing the Deed of Sale by misrepresenting it as a petition for US immigrant visas involves a factual question that the Supreme Court cannot delve into. The Court of Appeals had already resolved this factual issue, finding no adequate basis for the imputation of falsehoods. On the validity of the Deed of Absolute Sale and citizenship: The Court found no clear showing that Rogelio Surban had lost his Philippine citizenship when the property was sold to him. Amador Surban's claim that he believed the document was a petition for US immigrant visas was belied by his act of turning over the Deed of Extrajudicial Partition and the owner's copy of the title to Rogelio, which indicated a sale. Furthermore, the Deed of Absolute Sale was duly acknowledged and authenticated by the Vice-Consul in the Philippine Consulate in Guam, converting it into a public document. Public documents are entitled to full faith and credit unless proven otherwise by competent evidence showing defects or irregularities. The Court also noted that the Court of Appeals found no proof that Rogelio and Erlinda Surban were no longer Filipino citizens at the time of acquisition. On raising citizenship as a collateral issue: The Court held that the determination of whether a person has ceased to be a Filipino citizen is a momentous and far-reaching matter that should not be left to summary proceedings. It cannot be properly ventilated as a collateral issue in a complaint for Quieting of Title and Damages. Therefore, this issue could not be resolved in the present case.
Main Doctrine
The Supreme Court's jurisdiction under Rule 45 is limited to reviewing errors of law, not fact. A notarized deed of sale is a public document presumed authentic and admissible without further proof of authenticity, unless proven otherwise by competent evidence. Citizenship issues cannot be raised as a collateral issue in a complaint for Quieting of Title.