Gaje v. Dalisay
REITERATIONFacts
The Antecedents: Desiderio Dalisay, Sr. purchased two parcels of land in 1973, identified as Lot No. 729-A and Lot No. 729-F, with areas of 27,169 and 20,000 square meters respectively. Although the Deeds of Sale listed his son, Desiderio Dalisay, Jr., as the vendee for convenience, Dalisay, Sr. retained possession and control of the properties until his death in 1989. These lands were integrated into his corporation, Desidal Fruits, Inc., and were leased to Davao Premier Fruits Corporation. Following Dalisay, Sr.'s death, his widow, Patricia S. vda. de Dalisay, was appointed special administratrix of his estate and continued to possess and improve the lands, even donating a portion for a water system. Procedural History: In 1994, Desiderio Dalisay, Jr. executed Deeds of Sale for Lot No. 729-A to Silvano B. Gaje and Lot No. 729-F to Emilio C. Mellonida. Patricia S. vda. de Dalisay, as special administratrix, filed a complaint in 1995 with the Regional Trial Court (RTC) seeking to annul these deeds and reconvey the properties, asserting they were part of Dalisay, Sr.'s estate. The RTC ruled in favor of Patricia, declaring the deeds of sale void and the lands part of the estate. Dalisay, Jr. and his co-petitioners challenged the RTC's jurisdiction, but their motion to dismiss was denied, a decision affirmed by the Court of Appeals and subsequently by the Supreme Court. The RTC's decision was affirmed in toto by the Court of Appeals, which was then challenged by the petitioners in the present Supreme Court case. The Petition: The petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to overturn the Court of Appeals' decision. They argued that the appellate court erred in affirming the trial court's judgment that declared the Deeds of Sale in their favor as null and void, asserting they were buyers in good faith. Additionally, they contested the award of attorney's fees and costs without sufficient justification. The Supreme Court, however, found that the core of the petition involved a review of factual findings, which is generally outside its purview under Rule 45, as both lower courts consistently found Dalisay, Sr. to be the true owner based on substantial evidence. The Court affirmed the decisions regarding ownership but modified the ruling by deleting the award of attorney's fees due to lack of justification in the lower courts' decisions.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court's judgment declaring the Deeds of Sale in favor of the petitioners as null and void. Whether the Court of Appeals erred in not setting aside the award of attorney's fees and costs of suit.
Ruling
The Supreme Court partly granted the petition. It affirmed the Decision and Resolution of the Court of Appeals in toto, except for the award of attorney's fees, which was deleted. The Court declared the two Deeds of Sale between Desiderio Dalisay, Jr. and Emilio C. Mellonida, and between Desiderio Dalisay, Jr. and Silvano Gaje, as null and void. It also declared the subject parcels of land as part of the testate estate of the late Desiderio Dalisay, Sr.
Ratio Decidendi
On the first issue (Validity of Deeds of Sale): The Supreme Court held that the issue of ownership over the disputed properties is a question of fact, which is generally binding on the Supreme Court when affirmed by the Court of Appeals. The Court found that the evidence on record amply supported the decisions of the lower courts. The presumption of regularity of notarized documents, relied upon by the petitioners, is rebuttable and yields to clear and convincing evidence to the contrary. The Court noted that Dalisay, Jr. never possessed or exercised attributes of ownership over the lands from 1973 until he sold them in 1994, a period of twenty-one years. In contrast, Dalisay, Sr. possessed and utilized the lands as part of his business, Desidal Fruits, Inc., and later leased them to Davao Premier Fruits Corporation. Dalisay, Jr.'s silence when his mother, as administratrix, donated a portion of the property further contradicted his claim of ownership. The Court also ruled that the rule excluding extrinsic evidence in the construction of writings is inapplicable when one of the parties to the case is a stranger to the contract, as Patricia was to the Deeds of Sale. On the second issue (Attorney's Fees): The Supreme Court agreed with the petitioners that the award of attorney's fees was not sufficiently justified. Citing Article 2208(2) of the Civil Code and jurisprudence, the Court emphasized that an award of attorney's fees is an exception and requires justification in the body of the decision. Both the RTC and the Court of Appeals failed to provide any explanation or basis for the award of attorney's fees, merely stating it in the dispositive portion. Therefore, the award of attorney's fees in favor of the respondent was deleted.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' decision declaring the Deeds of Sale null and void, holding that the evidence on record sufficiently established that the deceased Desiderio Dalisay, Sr. was the owner of the subject parcels of land, despite the Deeds of Sale naming his son, Desiderio Dalisay, Jr., as vendee. The Court reiterated that the presumption of regularity of notarized documents is rebuttable and yields to clear and convincing evidence to the contrary. The Court also deleted the award of attorney's fees for lack of justification in the body of the lower courts' decisions.