Calahat v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Spouses Segundo Calahat and Norberta Prontes acquired a parcel of land (Lot No. 204) in 1937 through a private document of sale from spouses Francisco Codia and Tomasa Bugo. In 1954, private respondent Blas Calahat acquired a notarized Deed of Sale for the same lot from Francisco Codia, which was considered a ratification and confirmation of the 1937 sale. The heirs of Francisco Codia filed a complaint for annulment of the deed of sale and recovery of possession, which was dismissed by the trial court and affirmed by the Court of Appeals, upholding the sale to the Calahat spouses. In 1973, an extrajudicial settlement of the estate of Segundo Calahat and Norberta Prontes was executed among their heirs, including Lot No. 204. In 1976, Original Certificate of Title No. P-653 was issued in the name of Blas Calahat for Lot No. 204. In 1977, Suprema Calahat and Potenciana Calahat filed a petition for subdivision of Lot No. 204. Subsequently, Blas Calahat filed an amended complaint for Reformation of Extrajudicial Settlement, alleging he was the owner of Lot No. 204 by virtue of the 1954 sale and that the extrajudicial settlement did not express the true intention of the parties. He offered his sisters options to either reimburse his expenses, sell their rights, or exercise their rights within a reasonable time. Two sisters, Juana and Maura, sold their rights to Blas. Procedural History: The trial court declared the extrajudicial settlement null and void with respect to Lot 204, declared Blas Calahat the true owner and rightful possessor, ordered Suprema and Potenciana to vacate the premises, and awarded damages. The Court of Appeals affirmed the trial court's decision in toto. The Petition: Petitioners Potenciana and Suprema Calahat sought review of the Court of Appeals' decision, questioning the ownership of Lot No. 204.
Issue(s)
Whether Lot No. 204 belongs to respondent Blas Calahat by virtue of the notarized Deed of Sale dated September 11, 1954, or to the conjugal partnership of Segundo Calahat and Norberta Prontes by virtue of the unnotarized Deed of Sale dated July 3, 1937. Whether the extrajudicial settlement of estate, insofar as Lot No. 204 is concerned, is valid.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals. It ordered the Register of Deeds of Ozamiz City to cancel Original Certificate of Title No. D-653 and issue a new one in the names of Potenciana Calahat, Suprema Calahat, and Blas Calahat as co-owners with one-fifth and three-fifths interests, respectively.
Ratio Decidendi
On the ownership of Lot No. 204: The Court held that the issue of ownership of Lot No. 204 had already been resolved in Civil Case No. OZ-248, which was affirmed by the Court of Appeals. In that prior case, the trial court found that Lot No. 204 was sold by Francisco Codia and Tomasa Bugo to Segundo Calahat and Norberta Prontes in 1937 via a private document, and the 1954 notarized deed of sale executed by Francisco Codia in favor of Blas Calahat was merely a confirmation of the earlier sale. The Court reiterated the policy against multiplicity of suits, stating that an issue resolved in one case cannot be relitigated in a subsequent case, even if based on a different cause of action. The Court found no clear, convincing, and more than merely preponderant evidence to contradict the presumption of regularity of the notarized extrajudicial settlement. The private respondent's claim of pressure from a public prosecutor was unsubstantiated, as he failed to present the prosecutor as a witness. Furthermore, the private respondent's own complaint for reformation, by offering options to his sisters to sell their rights or reimburse him, implicitly admitted their interests in Lot No. 204. His allegation that his sisters Juana and Maura sold their respective rights and participation to him further supported the conclusion that they had existing interests in the property. Therefore, the Court concluded that Blas Calahat became the owner of three-fifths of the property after Juana and Maura conveyed their shares to him, while Potenciana and Suprema retained their respective shares. On the validity of the extrajudicial settlement: The Court found that the private respondent's claim that he was pressured into including Lot No. 204 in the extrajudicial settlement was not supported by evidence. The fact that he offered his sisters options to buy their shares or reimburse him implied that he acknowledged their interests. The Court also noted that it took him more than three years to question the settlement, suggesting a lack of genuine coercion. The Court's ruling on ownership effectively modified the extrajudicial settlement by recognizing the co-ownership of the siblings in Lot No. 204, thereby nullifying the trial court's declaration of absolute ownership in favor of Blas Calahat and the dismissal of the petition for subdivision based on laches.
Main Doctrine
A notarized deed of sale, being a public document, enjoys the presumption of regularity and requires clear, convincing, and more than merely preponderant evidence to contradict its contents. Furthermore, issues already resolved in a prior case cannot be relitigated in a subsequent case, even if based on a different cause of action, due to the policy against multiplicity of suits.