Naranja v. Belardo
REITERATIONFacts
The Antecedents: Roque Naranja was the registered owner of Lot No. 4 and a co-owner of Lot No. 2. He sold Lot No. 4 and his share in Lot No. 2 to his half-sister, Lucilia P. Belardo, on August 21, 1981, for P10,000.00 and other valuable consideration. Later, due to Belardo's inability to pay registration fees, Roque executed a second deed of sale for the same properties in favor of Margarita Dema-ala on November 19, 1983, for P30,000.00, to secure a loan. Roque died on December 2, 1983. Belardo eventually paid Dema-ala and recovered the titles. Procedural History: Unknown to Belardo, the heirs of Roque Naranja (petitioners) executed an Extrajudicial Settlement Among Heirs on October 11, 1985, adjudicating Lot No. 4 among themselves. They obtained Roque's copy of the title and had a new title issued in their names. Belardo, unable to register her deed of sale due to the cancellation of the original title, filed a suit for reconveyance with damages (Civil Case No. 7144). The petitioners also filed a suit for annulment of sale and quieting of title (Civil Case No. 7214). The Regional Trial Court (RTC) ruled in favor of the petitioners, declaring the deed of sale to Belardo null and void. The Court of Appeals (CA) reversed the RTC decision, declaring Belardo the sole owner and ordering the cancellation of the title issued to the heirs. The Petition: The petitioners seek review of the CA's decision and resolution, arguing that the deed of sale is invalid because it lacks a technical description of the properties as purportedly required by Act No. 496, that Roque's consent was vitiated, there was no conclusive showing of consideration, and there were serious irregularities in the notarization. They also question the validity of the deed of sale due to alleged undue influence, simulation, and lack of consideration.
Issue(s)
Whether the Deed of Sale is invalid for not complying with the provisions of Act No. 496. Whether the Deed of Sale is valid despite alleged vitiated consent, lack of consideration, and irregularities in notarization; and the effect on the subsequent Extrajudicial Settlement.
Ruling
The petition is denied. The Court of Appeals Decision dated September 13, 2002, and Resolution dated September 24, 2003, are affirmed.
Ratio Decidendi
On the validity of the Deed of Sale for non-compliance with Act No. 496: The Court held that a deed of sale need not contain a technical description of the subject property to be valid. Contracts of sale of real property follow the general rule that they may be entered into in any form, provided the essential requisites are present: consent, determinate subject matter, and price certain. The Deed of Sale clearly identified the properties by lot numbers, areas, and certificate of title numbers, making the subject matter determinable. Resort could be made to the technical descriptions in the certificates of title. Section 127 of Act No. 496 provides only a sample form, not a mandatory one. On the alleged nullity of the Deed of Sale due to vitiated consent, lack of consideration, and irregularities in notarization; and the effect on the subsequent Extrajudicial Settlement: The Court found that petitioners failed to submit sufficient proof of undue influence or simulation. A notarized document enjoys the presumption of regularity and must be sustained unless strong, complete, and conclusive proof of falsity or nullity is presented. The evidence did not show that Roque Naranja lost control of his mental faculties; his physical condition alone did not prove undue influence. The notary public attested that Roque was mentally sound. The late registration was explained by Belardo's lack of funds, which is plausible. The second deed of sale to Dema-ala was explained by the titles still being in Roque's name. The Deed of Sale itself contained an acknowledgment receipt, and the presumption of consideration cannot be overthrown by mere assertion. As heirs, petitioners are bound by the contract executed by their predecessor-in-interest, Roque Naranja. The properties were already sold to Belardo and thus did not form part of Roque's estate, rendering the subsequent Extrajudicial Settlement void.
Main Doctrine
A deed of sale, to be valid, requires the essential requisites of consent, determinate subject matter, and price certain. The absence of a technical description in a deed of sale does not invalidate it, as long as the subject property is determinable. Registration of the deed is necessary to bind third parties, but its absence does not affect the validity of the sale between the parties. Heirs are bound by contracts entered into by their predecessors-in-interest.