Dela Cruz v. Sison
REITERATIONFacts
The Antecedents: Epifania Dela Cruz (Epifania) filed a complaint to declare null and void a Deed of Absolute Sale dated November 24, 1989, executed in favor of respondents, Spouses Eduardo and Eufemia Sison. Epifania alleged that her nephew, Eduardo, tricked her into signing the deed by interspersing it among documents for the transfer of her residential land to her foster child, Demetrio Sison, Eduardo's brother. Epifania discovered the transfer of her rice land to Eduardo's name in 1992. Procedural History: The Regional Trial Court (RTC) ruled in favor of Epifania, declaring the deed of sale invalid and without legal force and effect, finding that Eduardo deceived Epifania. The Spouses Sison appealed to the Court of Appeals (CA), which reversed the RTC decision, declaring the Deed of Absolute Sale valid. The CA found Epifania's allegation of trickery to be bare and unsupported, and upheld the presumption of regularity of a duly notarized document. The Petition: Epifania, substituted by Laureana V. Alberto, filed a petition for review on certiorari, assailing the CA's decision and raising errors concerning the presumption of due execution, the validity of the deed, and the CA's disregard of the RTC's findings.
Issue(s)
Whether the Court of Appeals gravely erred in sustaining the presumption of due execution of the questioned Deed of Sale. Whether the Court of Appeals gravely erred in holding that the questioned Deed of Sale is valid. Whether the Court of Appeals gravely erred in not upholding the conclusions and findings of fact by the trial court.
Ruling
The petition is denied. The decision of the Court of Appeals declaring the Deed of Absolute Sale dated November 24, 1989, as valid is affirmed.
Ratio Decidendi
On the presumption of due execution and validity of the Deed of Sale: The Court affirmed the Court of Appeals' ruling that the Deed of Absolute Sale dated November 24, 1989, is valid. The Court reiterated the settled rule that documents acknowledged before notaries public are public documents that enjoy the presumption of regularity and due execution. To contradict this presumption, evidence that is clear, convincing, and more than merely preponderant is required. The burden of proof lies on the party contesting the validity of the notarial document, which the petitioner failed to discharge. Epifania never claimed her signatures were forgeries, only that she did not know she was signing a deed of sale for Eduardo. The Court found her allegations of trickery to be bare and unsupported by convincing evidence. On the validity of the Deed of Sale, considering Article 1332 of the Civil Code, alleged trickery, and Epifania's financial capacity: The Court found that Article 1332 of the Civil Code was not applicable because Epifania's claim of inability to read English was contradicted by her own statements. The Court found no trickery or fraud in the execution of the deed, noting significant differences between the deeds that would have been noticeable. The Court dismissed the argument that Epifania had no reason to sell, pointing out her decreased bank deposits and the sale of other properties, indicating a need for cash. On the Court of Appeals' findings versus the trial court's, and the ultimate validity of the Deed of Sale: While the Court normally defers to the findings of the appellate court, it may wade into factual disputes when the appellate court's findings contradict those of the trial court. In this case, after a careful perusal of the records, the Supreme Court sustained the Court of Appeals' ruling that the Deed of Absolute Sale is valid, finding that Epifania failed to provide sufficient evidence to overcome the presumption of regularity of the notarized document. The Court also considered Epifania's contemporaneous execution of a notarized "Affidavit of Seller/Transferor," official acts from the Department of Agrarian Reform (DAR), and Demetrio Sison's admission that Epifania sold the property to Eduardo, who had been in open and continuous possession since November 1989.
Main Doctrine
A deed of sale duly notarized enjoys the presumption of regularity and due execution. The party alleging fraud or trickery in its execution bears the burden of proving such claims with clear, convincing, and more than merely preponderant evidence. The presumption under Article 1332 of the Civil Code, which requires the party enforcing the contract to show that its terms were fully explained when a party is unable to read or understand the language, does not apply when the party alleging inability fails to satisfactorily establish such inability.