Domingo v. Court of Appeals
REITERATIONFacts
The Antecedents: Paulina Rigonan allegedly sold three parcels of land, along with a house and warehouse, to respondents Felipe and Concepcion Rigonan. Petitioners Eugenio Domingo, Crispin Mangabat, and Samuel Capalungan, claiming to be Paulina's closest surviving relatives, subsequently took possession of these properties. The Rigonan spouses filed a complaint for reinvindicacion (recovery of property), asserting ownership based on the deed of sale from Paulina Rigonan dated January 28, 1965, and alleging illegal entry by the petitioners. The petitioners contested this claim, asserting they inherited the properties as Paulina's kin and that the alleged deed of sale was spurious and lacked consideration. Procedural History: The complaint for reinvindicacion was filed by Felipe Rigonan in the Regional Trial Court (RTC) of Batac, Ilocos Norte. After consolidation with a cadastral case, the RTC rendered a decision on March 23, 1994, in favor of the petitioners (defendants), declaring them the lawful owners and possessors of the properties and deeming the deed of sale null and void. The private respondents appealed this decision to the Court of Appeals (CA). On August 29, 1996, the CA reversed the RTC's ruling, declaring the private respondents as the owners and ordering the petitioners to vacate the properties. The petitioners' subsequent motion for reconsideration was denied by the CA on December 11, 1996. The Petition: This petition for review on certiorari seeks to annul the decision and resolution of the Court of Appeals. The petitioners argue that the CA erred by disregarding the factual findings of the RTC, which were allegedly supported by unrebutted evidence. They contend that the CA's findings were based on speculation and overlooked crucial facts. Specifically, the petitioners challenge the validity of the deed of sale, citing the retraction of an instrumental witness, the failure to produce the original deed, discrepancies in its registration, the grossly inadequate consideration of P850 for multiple properties including a house and warehouse, and evidence suggesting Paulina Rigonan was senile and incapacitated at the time of the alleged sale.
Issue(s)
Whether the private respondents sufficiently established the existence and due execution of the Deed of Absolute and Irrevocable Sale of Real Property. Whether the Court of Appeals erred in reversing the factual findings of the trial court. Whether the alleged deed of sale was null and void due to lack of consideration and irregularities in its execution and registration.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision and resolution of the Court of Appeals, and reinstated the decision of the Regional Trial Court. The Court declared the deed of sale null and void and upheld the petitioners' ownership through intestate succession.
Ratio Decidendi
On the issue of the existence and due execution of the Deed of Absolute and Irrevocable Sale: The Supreme Court found that the private respondents failed to sufficiently establish the existence and due execution of the deed of sale. The primary evidence presented was a carbon copy, not the original typewritten deed. One of the alleged instrumental witnesses, Juan Franco, retracted his testimony during cross-examination, stating he did not sign the deed of sale. The testimony of the notary public, Atty. Tagatag, was deemed uncorroborated and self-serving. Furthermore, another witness, Efren Sibucao, was not presented, and his affidavit was withdrawn. The carbon copy itself contained filled-in blanks and alterations, and its registration was irregular, occurring after the alleged vendor's death. On the alleged errors of the Court of Appeals in reversing the trial court's factual findings: The Supreme Court held that the petition was properly given due course because the factual findings of the CA and the RTC were contradictory. The Court also noted that the CA apparently overlooked certain relevant facts which justified a different conclusion. The Court emphasized that while generally factual findings of the trial court are given great weight, exceptions exist, particularly when the appellate court's findings are not supported by evidence or when they contradict the trial court's findings established by unrebutted evidence. On the nullity of the deed of sale due to lack of consideration and irregularities: The Supreme Court agreed with the trial court that the deed of sale was null and void. The consideration of P850 for nine parcels of land, a house, and a warehouse was found to be grossly inadequate, especially considering the unrebutted testimony that the vendor, Paulina Rigonan, was financially well-off and had no apparent need for money. The Court also noted that Paulina Rigonan was of advanced age and senile at the time of the alleged execution, raising serious doubts about her capacity to consent to the sale and its terms. The absence of a receipt for the payment of the P850 further weakened the claim of a valid sale. The fact that the same properties were included in Paulina's will, notarized by the same notary public, also cast doubt on the genuineness of the sale.
Main Doctrine
The Supreme Court reversed the Court of Appeals, reinstating the trial court's decision that declared a deed of absolute sale null and void due to insufficient proof of due execution, lack of consideration, and irregularities in registration, thereby upholding the petitioners' claim through intestate succession.