Barrera v. Court of Appeals
REITERATIONFacts
The Antecedents: Azalia Salome owned a house and lot. She mortgaged it and later sold it to Rosendo C. Palabasan on July 1, 1966. A new Transfer Certificate of Title (TCT) No. 167387 was issued in Palabasan's name. Spouses Leoncio and Enriqueta Barrera claimed they had been in possession since 1962 under a Deed of Sale with Assumption of Mortgage, which was not notarized. They alleged Salome executed a notarized Deed of Sale with Assumption of Mortgage in their favor on March 31, 1966, and they settled Salome's obligations. They claimed they were surprised to learn in 1970 that a blank document they signed turned out to be a contract of lease with Palabasan as lessor. Procedural History: Spouses Barrera filed a complaint for reconveyance with damages against Palabasan. Palabasan asserted he validly bought the property from Salome after paying her obligation, and that the Barreras were his lessees. The Regional Trial Court (RTC) ruled in favor of Palabasan, applying Article 1544 of the Civil Code (double sale). The Court of Appeals (CA) affirmed the RTC decision, but found Article 1544 inapplicable due to insufficient proof of sale between Salome and the Barreras. The CA denied their motion for reconsideration. The Petition: The spouses Barrera filed a petition for certiorari seeking to annul the CA decision.
Issue(s)
Whether respondent Palabasan is the owner of the property in question. Whether there was a double sale of an immovable property covered by Article 1544 of the Civil Code.
Ruling
The petition is without merit. The Court denies the petition and affirms the decision of the Court of Appeals.
Ratio Decidendi
On whether respondent Palabasan is the owner of the property in question: The Court held that an action for reconveyance requires the claimant to prove by clear and convincing evidence their title to the property and the fact of fraud. Mere allegations of fraud are insufficient; intentional acts to deceive must be specifically alleged and proved. The petitioners failed to discharge this burden of proof. They offered no proof of misrepresentation or concealment in the registration of the deed leading to TCT No. 167387, and the presumption of regularity in official functions militates against their claim of fraud. Respondent Palabasan, conversely, presented TCT No. 167387, a Tax Declaration, a Deed of Absolute Sale dated June 30, 1966, a Contract of Lease, and a court decision finding him to be the lawful owner. The Court found TCT No. 167387 and the Tax Declaration more convincing than the petitioners' evidence. The certificate of title is considered absolute and indefeasible evidence of ownership. On whether there was a double sale of an immovable property covered by Article 1544 of the Civil Code: The Court found no sufficient proof of a sale between Salome and the petitioners to warrant the application of Article 1544. The notarized deed of sale dated March 31, 1966, was conditioned upon the petitioners' payment of Salome's mortgage obligation, a condition they failed to prove they complied with. Thus, the contract was not consummated. Evidence of an earlier transaction in 1962 was also insufficient; Salome's testimony was inadmissible due to lack of cross-examination, the deed was not notarized, and counsel for the petitioners admitted the transaction did not materialize. The only sale that materialized was that to respondent Palabasan, evidenced by a deed of absolute sale, which allowed him to redeem the property and secure title.
Main Doctrine
An action for reconveyance requires proof of title and fraud by clear and convincing evidence. Mere allegations of fraud are insufficient. A certificate of title is strong evidence of ownership. There is no double sale if one of the purported sales is not sufficiently proven to have been consummated.