Francisco v. Francisco-Alfonso
REITERATIONFacts
The Antecedents: Respondent Aida Francisco-Alfonso is the sole legitimate daughter of the deceased Gregorio Francisco. Petitioners Regina Francisco and Zenaida Pascual are illegitimate daughters of Gregorio Francisco with his common-law wife, Julia Mendoza. Gregorio Francisco owned two parcels of land. After his death, Aida learned that Gregorio had executed a deed of absolute sale for these lands to petitioners on August 15, 1983, for P25,000.00, resulting in new titles being issued to Regina and Zenaida. Procedural History: Aida Francisco-Alfonso filed a complaint against Regina Francisco and Zenaida Pascual with the Regional Trial Court (RTC) of Bulacan, seeking the annulment of the deed of sale and damages, alleging that her father's signature on the deed was a forgery. The RTC dismissed Aida's complaint, upholding the validity of the deed of sale and the transfer certificates of title. Aida appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's decision, declaring the deed of sale null and void, annulling the transfer certificates of title, ordering the reinstatement of the original titles in Gregorio Francisco's name, and awarding damages and attorney's fees to Aida. The Petition: Petitioners Regina Francisco and Zenaida Pascual filed a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to overturn the decision of the Court of Appeals. They primarily question whether the Supreme Court can review the factual findings of the appellate court. The Supreme Court noted that its jurisdiction under Rule 45 is limited to errors of law and that it does not re-examine evidence unless the lower court's findings are unsupported or glaringly erroneous. The Court affirmed the CA's decision, finding the deed of sale to be simulated due to lack of consideration and also noting that the sale, even if valid, would infringe upon respondent's legitime as a legitimate daughter.
Issue(s)
Whether the Supreme Court may review the factual findings of the Court of Appeals. Whether the deed of sale was simulated for lack of consideration. Whether the sale, even if not simulated, violated the Civil Code provisions regarding the legitime of the respondent.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the issue of reviewing factual findings: The jurisdiction of the Supreme Court in cases brought from the Court of Appeals under Rule 45 of the Revised Rules of Court is limited to the review of pure errors of law. The Court does not re-examine or re-weigh evidence unless the findings of the lower court are totally devoid of support or are glaringly erroneous as to constitute grave abuse of discretion. In this case, the petitioners failed to prove that the case falls within any of the recognized exceptions, thus the factual findings of the Court of Appeals, being supported by substantial evidence, are conclusive and binding. On whether the deed of sale was simulated: The Court affirmed the Court of Appeals' finding that the kasulatan (deed of sale) was simulated due to lack of consideration. Evidence presented showed that petitioners Regina Francisco and Zenaida Pascual had no credible source of income in 1983 sufficient to purchase the properties for P25,000.00. Their testimonies regarding their earnings from operating a canteen, working as a cashier, and selling ready-to-wear items, or from being a market vendor selling nilugaw, were found to be incredible and insufficient to support the purchase price. The lack of a single witness to the kasulatan to prove receipt of the purchase price further supported the conclusion that there was no actual consideration for the sale, rendering it null and void from the beginning. On whether the sale violated the Civil Code provisions on legitime: Even if the kasulatan were not simulated, the Court found that the transaction violated the Civil Code provisions concerning the legitime of compulsory heirs. The sale was executed in 1983, during which the Civil Code was the applicable law. The sale was clearly Gregorio Francisco's method of transferring his property to his illegitimate daughters at the expense of his legitimate daughter, Aida. By law, Aida, as the sole legitimate child, is entitled to one-half of her father's hereditary estate. If these parcels of land were the only property left by Gregorio, the sale would deprive Aida of her rightful share in her father's estate. Compulsory heirs cannot be deprived of their share except through disinheritance as prescribed by law, which was not the case here.
Main Doctrine
A deed of sale is considered simulated and null and void from the beginning if there is no consideration for the contract. Furthermore, a simulated sale intended to deprive a legitimate child of their legitime violates the Civil Code provisions on succession.