Facts:

The case revolves around the dispute between Leonardo Acabal and Ramon Nicolas (petitioners) against Villaner Acabal and other family members (respondents). The events leading up to the case began on April 19, 1990, when Villaner Acabal executed a document that is now in question. Villaner's parents, Alejandro Acabal and Felicidad Balasabas, had acquired an 18.15-hectare parcel of land in Barrio Tanglad, Manjuyod, Negros Oriental, through a Deed of Absolute Sale on July 6, 1971. By the time of the dispute, Villaner was a widower, having lost his wife Justiniana Lipajan.

On April 19, 1990, he executed a deed, which he later claimed was a lease agreement for the property to his nephew Leonardo for three years at P1,000 per hectare, albeit this document was presented as a Deed of Absolute Sale witnessed by a trial court clerk and his wife. Villaner argued in his testimony that he believed he was signing a lease agreement as it resembled one made in the past. He filed a complai

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Facts:

Parties and Background

• The dispute involves respondent Villaner Acabal and petitioners Leonardo Acabal and Ramon Nicolas.
• Villaner, originally a beneficiary of a property acquired by his parents through a sale in 1971, executed a document on April 19, 1990, in favor of Leonardo Acabal.
• The subject property is located in Barrio Tanglad, Manjuyod, Negros Oriental, covering approximately 18.15 hectares as described in Tax Declaration No. 15856.

Nature of the Executed Document

• Villaner’s execution of the document is disputed: he claims it was a lease contract, while Leonardo contends it was a Deed of Absolute Sale.
• Evidence indicates that the document was prepared in a manner similar to a previous lease agreement (modeled after a July 1976 lease with Maria Luisa Montenegro) but later appears as a deed of sale.
• Conflicting testimonies emerged regarding the nature of the document, including differing accounts about the identity and signatures of the witnesses.

Testimonies and Documentary Evidence

• Villaner testified that he did not read beyond the title of the document and maintained that he agreed only to lease the property rather than selling it.
• Witnesses such as Carmelo Cadalin, and employees of Judge Villegas provided evidence with contradictory statements regarding their roles, the execution, and notarization of the document.
• Notarization testimony from Atty. Vicente Real, who noted procedural lapses, further complicated the characterization of the document.

Procedural History and Subsequent Transactions

• Villaner filed a complaint before the Regional Trial Court on October 11, 1993 seeking annulment of the deeds executed by Leonardo.
• The trial court ruled in favor of petitioners Leonardo and Ramon Nicolas, a decision that was later reversed by the Court of Appeals, which held the document to be simulated and fictitious.
• On appeal, Leonardo and Ramon Nicolas presented a petition for review on certiorari contesting both the procedural and substantive rulings of the Court of Appeals.

Property Characteristics and Co-ownership Issues

• The property, acquired originally during Villaner’s marriage to Justiniana Lipajan, later became the subject of co-ownership issues following her death.
• The disputed property, with conflicting tax declarations and differing descriptions in the documents, was later transferred through subsequent sale to Ramon Nicolas.
• Co-ownership implications arose since the property was deemed conjugal, and its sale by one party without the consent of the other co-owners raised issues of alienation of an undivided share.

Issue:

Nature and Validity of the Document

• Whether the April 19, 1990 document executed by Villaner is a valid Deed of Absolute Sale or a simulated/altered Lease Contract as alleged by Villaner.
• Whether the document’s form and the manner in which it was executed (including the involvement of allegedly misidentified witnesses) affect its validity.

Adequacy of Consideration and Fraud Allegations

• Whether the consideration of P10,000.00 is unusually low, thereby suggesting fraud or lack of valid consent in the transaction.
• Whether Villaner’s failure to provide clear and convincing evidence to substantiate his claim of being deceived negates his arguments of fraud.

Procedural and Evidentiary Issues

• Whether the Court of Appeals erred in not applying Section 8, Rule 8 of the Rules of Court regarding the defense of the genuineness and due execution of an actionable document.
• Whether Villaner’s delayed objection to the possession and ownership by petitioner Ramon Nicolas, after the latter had enjoyed almost three years of uninterrupted possession, should bar his claims.

Good Faith and Co-ownership Concerns

• Whether petitioner Ramon Nicolas is a bona fide purchaser in good faith despite the alleged irregularities in the transaction.
• Whether Villaner’s subsequent sale of the entire property, as a co-owner without the consent of the other co-owners, can be deemed valid under the law.

Application of Agrarian Reform Law

• Whether the disposition of the property, considering its agricultural and non-agricultural characteristics, was subject to the retention limits imposed by Republic Act No. 6657 and if such disposition is void for that reason.

Determination of Remedial Measures

• Whether the remedy ordered by the lower court for the payment of rental from 1990 until the vacation of the premises is proper in light of the established facts and applicable law.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)