Uy v. Lacsamana
REITERATIONFacts
The Antecedents: The subject property is Lot 5506 (484 sq.m.) under TCT No. T-24660 formerly in the name of Spouses Anastacio Manuel and Mariquita de Villa. According to the complaint, the property was acquired in 1964 and registered in the name of Petra Rosca, described as "married to Luis G. Uy." A house was built on the property. On 18 April 1979 a Deed of Sale was executed by Rosca in favor of Spouses Lacsamana for P80,000. The Register of Deeds elevated a registrability question to the Land Registration Commission (LRC) which, in LRC Consulta No. 1194, resolved on 7 November 1979 that the document should be admitted for registration. Rosca later obtained a real estate loan in 1976 and executed an Affidavit of Ownership describing herself as sole owner; Spouses Lacsamana subsequently mortgaged and later sold the property to Corazon Buena in December 1982. Procedural History: On 4 May 1979 petitioner Uy filed a Complaint for Declaration of Nullity of Documents with Damages in the Regional Trial Court (RTC), Branch 4, Pallocan West, Batangas City. The RTC rendered judgment on 21 April 2009 dismissing Uy’s complaint, finding no valid marriage and upholding the sale. Uy appealed to the Court of Appeals (CA) (docketed CA-G.R. CV No. 93786). The CA, in a Decision dated 14 September 2011, affirmed the RTC. The CA denied Uy’s motion for reconsideration in a Resolution dated 1 March 2013. Uy filed a petition for review on certiorari under Rule 45 before the Supreme Court. The Petition: Uy contends the 18 April 1979 Deed of Sale is simulated or fictitious for lack of consideration and lack of his marital consent, that the buyers were not in good faith, and that the property should be considered conjugal/co-owned. Respondents assert the factual findings of the RTC and CA are supported by substantial evidence and that under Rule 45 only questions of law may be raised before the Supreme Court.
Issue(s)
Whether the Deed of Sale dated 18 April 1979 executed by Petra Rosca alone, without the consent of Luis Uy, is valid. Whether Spouses Lacsamana and Corazon Buena qualify as buyers in good faith. Whether the subject property is paraphernal to Rosca or co-owned/conjugal under Article 147 of the Family Code. Whether the Supreme Court may re-examine the factual findings of the RTC and CA under Rule 45 in this petition for review on certiorari.
Ruling
The petition is DENIED. The Decision dated 14 September 2011 and Resolution dated 1 March 2013 of the Court of Appeals in CA-G.R. CV No. 93786 are AFFIRMED. The Supreme Court found the Deed of Sale valid, held that the property was paraphernal to Rosca, and that the buyers were in good faith. The Court further held that under Rule 45 it will not re-evaluate factual findings supported by substantial evidence.
Ratio Decidendi
On Whether the Deed of Sale is valid: The Court held that the Deed of Sale executed by Rosca is valid because the record established that the subject property was Rosca's paraphernal property and she had the right to dispose of it without Uy's consent. The Court relied on documentary evidence, the LRC Resolution admitting the document for registration, Rosca's Affidavit of Ownership, and the deed where Uy was a mere witness, which together overcame the presumption of co-ownership under Article 147. The Court emphasized that questions regarding payment of the purchase price and the factual circumstances surrounding the sale are factual matters that were thoroughly examined by the RTC and CA and are supported by substantial evidence; therefore, they are not proper subjects for review under Rule 45. Applying the presumption-of-marriage doctrine and its exceptions, the Court found that Uy failed to prove a valid marriage and thus could not invoke conjugal property rules to invalidate the sale. Consequently, the sale is valid and executed by the registered owner acting on her paraphernal title. On Whether Spouses Lacsamana and Buena are buyers in good faith: The Court found no convincing proof by Uy that the buyers did not pay consideration or that the price was unconscionably low. The appellate factual findings that payment occurred and that the buyers relied on the Torrens title were supported by the record and binding on the Supreme Court absent an exception to Rule 45. The Court noted that Uy presented no documentary or testimonial evidence of the fair market value at the time of sale to substantiate a claim of unreasonably low consideration. The Court further observed that the buyers relied on the registered title and subsequent transactions (mortgage and sale to Buena) which are consistent with ordinary dealings in good faith under Torrens system jurisprudence, such as cited in Pisuena and Ruiz. Because challenges to the existence or adequacy of consideration are factual, they could not be re-litigated in this Rule 45 petition. On Whether the property is paraphernal or co-owned under Article 147: The Court applied Article 147 of the Family Code but concluded that Rosca had produced sufficient evidence to overcome the presumption of co-ownership. The LRC Resolution, the Deed of Sale in which Uy signed only as a witness, the Affidavit of Ownership for a loan, and the registration in Rosca’s name were determinative in establishing paraphernal ownership. The Court cited Pisuena v. Heirs of Unating and Ruiz v. Court of Appeals for the proposition that wording such as "Petra Rosca, married to Luis G. Uy" is descriptive of civil status and does not automatically make the husband a co-owner on the certificate of title. The Court reasoned that since Rosca established ownership and Uy failed to rebut with superior evidence, Rosca's paraphernal title remained intact and she could validly alienate the property. On Whether the Supreme Court may re-examine factual findings under Rule 45: The Court reiterated that petitions for review on certiorari under Rule 45 are limited to questions of law; factual findings of trial and appellate courts supported by substantial evidence are binding. The Court cited the well-established principle that it is not a trier of facts and that Uy’s attempts to re-open factual issues (e.g., existence of marriage, payment of consideration, possession) could not be entertained absent recognized exceptions to Rule 45. The Court therefore declined to reassess credibility and weight of evidence, finding no compelling reason or exception to disturb the RTC and CA factual conclusions.
Main Doctrine
Presumption of marriage and protection of registered paraphernal title; limitation of Supreme Court review under Rule 45 to questions of law