Pascual v. Fajardo
REITERATIONFacts
The Antecedents: Petitioner Maura Pascual and respondent Conrado Fajardo lived together as husband and wife without the benefit of marriage from 1971 to 1991. On October 15, 1982, Fajardo purchased a parcel of land in Sta. Barbara, Baliuag, Bulacan, with an area of 13,929 square meters, covered by TCT No. T-41670. In 1991, Fajardo discovered falsified documents perpetrated by Pascual, including deeds of sale transferring ownership of his property to her, and a TCT No. 288789 issued in her name for a 3,000-square meter portion of the property. These documents were allegedly executed in Cabanatuan City and notarized by Atty. Primitivo B. Punzalan. Procedural History: Enraged by these findings, Fajardo separated from Pascual and filed a complaint for falsification of private documents. Subsequently, Fajardo and Daniel Gregorio filed a civil case for nullification of the questioned Deeds of Sale, cancellation of TCT No. 288789, and damages against Pascual. Conrado Fajardo died on July 10, 1991, and was substituted by his children. The Regional Trial Court (RTC) rendered a decision in favor of the plaintiffs, declaring the deeds of sale null and void, ordering the cancellation of TCT No. 288789, reconveyance of the property, accounting for rentals, and payment of damages. The Court of Appeals affirmed the RTC's decision with modifications on the award of damages. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' decision, raising factual issues regarding the nullification of deeds of sale, cancellation of title, reconveyance, and damages.
Issue(s)
Whether the Court of Appeals erred in nullifying the Deed of Absolute Sale executed by Josefina Jacinto on August 2, 1978. Whether the Court of Appeals erred in nullifying the Deeds of Sale executed by Conrado Fajardo in favor of petitioner. Whether the Court of Appeals erred in ordering the cancellation of TCT No. T-288789 and the reconveyance of the subject lots to respondents. Whether the Court of Appeals erred in ordering petitioner to account for and turn over the rents to respondents and to pay them damages.
Ruling
The Supreme Court denied the petition and affirmed the challenged Decision of the Court of Appeals. The Court held that the issues raised by the petitioner were factual in nature and beyond the scope of a petition for review on certiorari under Rule 45. The factual findings of the trial court, affirmed by the Court of Appeals, are binding and conclusive upon the Supreme Court.
Ratio Decidendi
On the nullification of the Deed of Absolute Sale executed by Josefina Jacinto on August 2, 1978: The Court affirmed the lower courts' findings that this deed was null and void. The testimony of the witness, Daniel Gregorio, denouncing his signature as a forgery, was given credence. Gregorio testified that the sale transaction between Fajardo and Jacinto over the same property took place in 1982, contradicting the date on the deed. Petitioner failed to present substantial evidence to refute Gregorio's claim. The trial court found no reason to doubt Gregorio's veracity, establishing his association with both Fajardo and Jacinto. On the nullification of the Deeds of Sale executed by Conrado Fajardo in favor of petitioner: The Court upheld the lower courts' declaration that these deeds were void. A significant factor was the dubious notarial authority of Atty. Primitivo B. Punzalan, who notarized the documents. Atty. Punzalan was employed with the PNB at the time, and government lawyers are generally prohibited from engaging in the practice of notary public without specific written authority, which was not shown. Furthermore, Atty. Punzalan could not account for copies of the deeds, and verification from the Bureau of Archives revealed he had no notarial record for the questioned deeds. Rebuttal witnesses also denied any transaction with Atty. Punzalan concerning the parcels of land they purchased from Conrado Fajardo, further casting doubt on the authenticity of the documents. On the cancellation of TCT No. T-288789 and reconveyance of the subject lots: The Court affirmed the order for cancellation and reconveyance based on the finding that the underlying deeds of sale were void. Since the deeds used to transfer ownership and secure the title were declared null and void, the title derived from them is also tainted. The reconveyance was ordered to restore the property to its rightful owners, the heirs of Conrado Fajardo, as the fraudulent transfer could not divest them of their ownership rights. On the order to account for rents and pay damages: The Court sustained the order for petitioner to account for and return all proceeds from monthly rentals collected, as well as to pay damages. This was a consequence of the nullification of the deeds of sale and the fraudulent transfer of property. The award of damages, as modified by the Court of Appeals, was deemed proper to compensate the respondents for the losses and moral suffering caused by the petitioner's fraudulent acts.
Main Doctrine
The Supreme Court will not disturb factual findings of the trial court affirmed by the Court of Appeals, absent any showing of grave abuse of discretion or overlooking of essential facts that could alter the outcome. Factual issues are beyond the scope of a petition for review on certiorari under Rule 45.