Constantino v. Court of Appeals
REITERATIONFacts
The Antecedents: Josefa Torres died intestate, leaving a parcel of land. Her heirs (respondents) entered into a contract to sell a portion of this land to petitioner Nelia A. Constantino. The heirs authorized petitioner to prepare the Deed of Extrajudicial Settlement of Estate with Sale. The heirs signed the draft deed with the understanding that one of the heirs, Aurora S. Roque, would be present during the survey and when permission was sought from the Bureau of Lands. However, without the participation of the heirs, the property was surveyed, subdivided, and covered by new Transfer Certificates of Title (TCT Nos. T-292265 and T-292266). Petitioner did not provide the heirs with copies of the deed, subdivision plan, or titles. Upon obtaining a copy of the deed, the respondents discovered that the area sold to petitioner was larger than agreed upon, including a portion occupied by spouses Severino and Consuelo Lim, which was subject to a prior agreement to sell. Procedural History: On June 2, 1986, private respondents demanded the surrender of the documents from petitioner, but to no avail. On June 25, 1986, respondents filed an action for annulment of the deed and cancellation of titles with damages before the Regional Trial Court (RTC) of Bulacan. The RTC, finding serious doubts regarding the preparation and due execution of the deed, ordered the annulment and cancellation of the deed, titles, and subdivision plan, and awarded damages and attorney's fees. The Court of Appeals (CA) affirmed the RTC decision on March 16, 1994, and denied the motion for reconsideration on June 20, 1994. The Petition: Petitioner appealed to the Supreme Court, faulting the CA for disregarding documentary evidence on a technicality and for concluding that the deed did not reflect the true intent of the parties.
Issue(s)
Whether the trial court erred in denying petitioner's motion to admit formal offer of evidence on the ground of late filing. Whether the Deed of Extrajudicial Settlement of Estate with Sale reflected the true intent of the parties and was validly executed. Whether fraud vitiated the consent of the respondents in the execution of the deed.
Ruling
The petition is DENIED. The decision of the Court of Appeals, which affirmed the decision of the Regional Trial Court, is affirmed.
Ratio Decidendi
On the denial of the motion to admit formal offer of evidence: The trial court correctly held that petitioner waived her right to formally offer evidence. Petitioner's counsel was granted 15 days to submit the offer of evidence, but failed to do so. After a considerable lapse of time (approximately three months), the motion to admit the offer was filed out of time, and after the opposing party had already filed their memorandum. To grant the motion would condone laxity and encourage delays, hindering the speedy administration of justice. The rules of procedure are tools to secure substantial justice, not to override it, but their application must be balanced with the need for orderly court proceedings. The trial court's decision to deem the right waived was a reasonable exercise of its discretion. On the validity and true intent of the Deed of Extrajudicial Settlement of Estate with Sale: The Supreme Court found that the deed did not reflect the true intent of the parties and was vitiated by fraud. The respondents' claim that they signed the document before the land was surveyed and before the area to be sold was determined was given credence. This was supported by the fact that petitioner's own witness testified that the survey was conducted six days after the purported signing date. The deed contained blank spaces, particularly regarding the dimensions of the property, indicating it was incomplete at the time of signing. The respondents were allegedly induced to sign based on petitioner's assurance that a co-heir would be present during the survey, which turned out to be a ruse. Furthermore, the fact that the deed was notarized in Manila, despite the parties and the property being in Bulacan where notaries public are readily available, cast doubt on the procedural regularity and the claim that the respondents appeared before the notary public. The handwritten entries on the deed regarding the subdivision plan and areas, contrasting with the typewritten text, also suggested these details were not available at the time of formalization. On the issue of fraud: The Court concluded that all elements of fraud vitiating consent were present. Fraud was employed by the petitioner upon the respondents, inducing them to enter into the contract. The fraud was serious, as it involved misrepresentation about the survey and the extent of the property sold, and it resulted in damages and injury to the respondents, who were deprived of a portion of their inheritance. The petitioner's actions of filling in blank spaces, subdividing the lots, and securing new titles without the respondents' knowledge or consent constituted deceit.
Main Doctrine
A contract may be annulled on the ground of fraud if it was employed by a contracting party upon the other, induced the latter to enter into the contract, was serious, and resulted in damages and injury to the party seeking annulment. The failure to comply with procedural rules, such as the timely filing of a formal offer of evidence, can lead to the waiver of the right to present such evidence.