Yason v. Arciaga
REITERATIONFacts
The Antecedents: Spouses Emilio and Claudia Arciaga sold Lot No. 303-B to spouses Dr. Jose and Aida Yason via a Deed of Conditional Sale on March 28, 1983, and a Deed of Absolute Sale on April 19, 1983, for ₱265,000.00. Claudia Arciaga died on the same day the Deed of Absolute Sale was executed. Petitioners registered the deed, but an intermediary, Jesus Medina, falsified it to appear that the sale occurred on July 2, 1979, for ₱25,000.00, leading to the issuance of new titles in petitioners' names. Petitioners subdivided the lot and sold some portions. Procedural History: In April 1989, respondents (children of Emilio and Claudia Arciaga) learned of the falsification and filed a complaint for falsification, which was dismissed for lack of probable cause. Subsequently, respondents filed a civil complaint for annulment of the 13 land titles, alleging the Deed of Absolute Sale was void due to lack of Claudia's consent (as she was ill and died on the day of execution) and Medina's falsification. The Regional Trial Court (RTC) dismissed the complaint, upholding the validity of the sales. The Court of Appeals (CA), in an Amended Decision, declared the Deed of Absolute Sale void for lack of Claudia's consent and ordered the cancellation of titles. The CA reversed its initial decision upon respondents' motion for reconsideration. The Petition: Petitioners seek review of the CA's Amended Decision, arguing it erred in declaring the Deed of Absolute Sale void for lack of consent and for being forged.
Issue(s)
Whether the Court of Appeals erred in declaring the Deed of Absolute Sale void for lack of consent on the part of Claudia Arciaga. Whether the Court of Appeals erred in declaring the Deed of Absolute Sale void because the same document was forged by Jesus Medina.
Ruling
The petition is impressed with merit. The Court reversed the Court of Appeals' Amended Decision and affirmed the RTC's Decision dismissing the respondents' complaint. The Deed of Absolute Sale dated April 19, 1983, was declared valid.
Ratio Decidendi
On the issue of lack of consent on the part of Claudia Arciaga: The Court held that while Claudia Arciaga was sick and bedridden, the respondents failed to present clear and convincing evidence that she could no longer understand the terms of the contract or that she did not affix her thumbmark thereon. The absence of a doctor's or nurse's testimony to confirm her incapacity was noted. Mere weakness of mind or physical infirmity does not automatically incapacitate a person from entering into a contract unless it impairs their mental faculties to the extent that they cannot understand the provisions of the contract. The Court also stated that it is of no moment that Claudia merely affixed her thumbmark, as a signature can be made by a mark. There was no evidence of coercion or force. The Court found the petitioners' claim that Claudia died in the evening of April 19, 1983, more credible, allowing for the possibility of her affixing her thumbmark in the morning. On the issue of the Deed of Absolute Sale being forged by Jesus Medina: The Court noted that the respondents' insistence on the falsity of the deed was based on the alleged inconsistency between Virginia Arciaga's testimony (notarization at home) and Atty. Jaime Fresnedi's testimony (notarization at his office). However, the Court found this inconsistency understandable given the nine-year lapse of time and the numerous documents Atty. Fresnedi must have notarized. The Court reiterated the principle that a notarized document enjoys the presumption of regularity and must be sustained unless impugned by strong, complete, and conclusive proof of falsity or nullity. The respondents failed to present such proof. Therefore, the Court concluded that there was consent on the part of Claudia Arciaga, and the Deed of Absolute Sale is valid.
Main Doctrine
A notarized deed of sale carries the presumption of regularity and evidentiary weight regarding its execution. The burden of proving lack of capacity to contract rests on the party alleging it, requiring clear and convincing evidence. Mere physical infirmity does not automatically incapacitate a person from entering into a contract unless it impairs their mental faculties.