Llana v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents initiated an action to quiet title against petitioners, asserting ownership over six parcels of land in Ilocos Norte. They claimed to have purchased these lots from the petitioners through various deeds of sale executed in 1966. Additionally, private respondents alleged that the deceased husband of petitioner Aurelia Llana, Bonifacio Llana, owed Nicanor Pagdilao a P5,000.00 loan with interest, which remained unpaid. Petitioners countered that they remained the owners of the lots, asserting that the deeds of sale were simulated and executed due to misrepresentations by Nicanor Pagdilao. They claimed the transfers were merely for paper purposes to prevent the properties from being attached in a homicide case against Bonifacio Llana. Petitioners also contended that the alleged debt was settled in 1966 by the conveyance of two other lots. Procedural History: The private respondents filed their action to quiet title in the Court of First Instance (CFI) of Ilocos Norte, Branch IV, in 1974. On September 2, 1982, the CFI rendered a decision declaring the private respondents as owners of the lots, ordering the petitioners to deliver possession, enjoining them from trespassing, and awarding damages for lot rentals and produce. The CFI also ordered the defendant Bonifacio Llana to pay the P5,000.00 debt with interest. The petitioners appealed this decision to the Court of Appeals. On March 23, 1992, the Court of Appeals affirmed the CFI's decision in its entirety, finding that the petitioners failed to present clear and convincing proof that the deeds of sale were simulated. The Petition: Petitioners seek review of the Court of Appeals' decision via a petition for review on certiorari under Rule 45 of the Revised Rules of Court. They raise two main issues: first, that the Court of Appeals erred in giving credence to the absolute deeds of sale when parol testimony purportedly proved they did not reflect the parties' true intentions; and second, that the Court of Appeals erred in not dismissing the second cause of action concerning the alleged unpaid debt. Petitioners essentially ask the Supreme Court to re-examine the factual findings of the lower courts regarding the validity of the deeds of sale and the settlement of the debt.
Issue(s)
Whether the Court of Appeals gravely erred in giving credence to the absolute deeds of sale when parol testimony purportedly proved that the documents did not reflect the true intention of the parties. Whether the Court of Appeals gravely erred in not dismissing the second cause of action.
Ruling
The petition is dismissed, and the Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the validity of the deeds of sale: The Supreme Court reiterated that it is not a trier of facts, and the factual findings of the Court of Appeals, especially when affirming those of the trial court, are conclusive. The Court noted that the conveyance of the lots was evidenced by duly notarized deeds of sale. While parol evidence is admissible to assail the validity of a written agreement, the petitioners failed to present clear and convincing evidence to overcome the presumption of regularity afforded to notarized documents. The testimony of petitioner Aurelia Llana, being an interested party, was deemed insufficient and self-serving without corroborating proof. Therefore, the validity of the deeds of sale was upheld. On the second cause of action (loan): Similar to the issue of the deeds of sale, the Court found no evidence other than Aurelia Llana's testimony to prove that Bonifacio Llana had paid the P5,000.00 debt plus interest to Nicanor Pagdilao. The deed of sale for the two lots in Barangay Nagbacsayan did not indicate that these were conveyed in payment of the debt. Consequently, the claim that the debt was paid was not substantiated, and the ruling on the second cause of action was sustained.
Main Doctrine
A notarized deed of sale enjoys the presumption of regularity and is prima facie evidence of the facts stated therein. To overcome this presumption, evidence that is clear, convincing, and more than merely preponderant must be presented. Self-serving statements and the testimony of an interested party are generally insufficient to impugn the validity of a notarized document.