G.R. No. 155043 - Abalos vs. Macatangay, Jr.

Spouses Arturo and Esther Abalos are registered owners of a 327-sqm parcel with improvements in Makati City (TCT No. 145316).
On June 2, 1988, Arturo obtained a Special Power of Attorney (SPA) from Esther, and on October 17, 1989, he executed a Receipt and Memorandum of Agreement (RMOA) binding himself to sell the property to respondent Dr. Galicano S. Macatangay, Jr., at a price of ₱1,300,000.00, with a ₱5,000.00 earnest-money check.

On October 25, 1989, Esther executed another SPA in favor of her sister to effect the transfer.
Respondent annotated an adverse claim on the title (Nov. 14, 1989) and, on Nov. 16, demanded full payment and possession, prompting Esther (through attorney-in-fact) to execute a Contract to Sell her conjugal interest for ₱650,000.00 (net of earnest money), with the balance of ₱1,290,000.00 payable after possession.
On December 7, 1989, respondent set aside a Citibank check for ₱1,290,000.00, reiterated the demand, but the spouses failed to deliver possession, leading to a second annotation and the filing of a specific-performance complaint on January 12, 1990.

The Regional Trial Court dismissed the complaint, finding the SPA to be a forgery, the RMOA unsupported by valid consideration, and the earnest-money check dishonored.
The Court of Appeals reversed, holding the SPA by Esther validly empowered her sister to sell her share and that the RMOA bound Arturo’s conjugal share.
Petitioner Arturo Abalos elevated the case to the Supreme Court, alleging (a) denial of due process, (b) erroneous reversal of trial-court findings, and (c) mischaracterization of the contracts.

Was petitioner denied due process in the Court of Appeals proceedings?
Did the Court of Appeals commit grave error in setting aside the trial court’s factual findings?
Are the RMOA and the Contract to Sell valid contracts of sale warranting specific performance?