Title
Arambulo vs. Court of Appeals
Case
G.R. No. 120166
Decision Date
Aug 3, 1998
Arambulo contested Flores' ownership claim, alleging forged documents and a falsified deed of sale. The Supreme Court ruled in Arambulo's favor, declaring the deed void and restoring his title.
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Case Digest (G.R. No. 120166)

Facts:

Ownership and Title Dispute:

  • Petitioner Dominador Arambulo claimed ownership of a parcel of agricultural land in Nueva Ecija, covered by Transfer Certificate of Title (TCT) No. NT-21357.
  • He alleged that his title was illegally cancelled in favor of respondent Flora Flores based on a falsified deed of sale, which he never executed.

Falsified Documents:

  • Arambulo asserted that Flores used fictitious documents, including:
    1. A petition for the issuance of a second owner’s copy of TCT No. NT-21357, falsely claiming the original was lost.
    2. A spurious court order dated September 20, 1984, allegedly issued by Judge Domingo Garcia.
    3. A fake certification dated October 9, 1984, signed by Acting Branch Clerk of Court Rosalinda Adrineda.
  • These documents were used to secure TCT No. NT-187175 in Flores’ name.

Trial Court Findings:

  • The trial court found that:
    1. Arambulo was the registered owner of the land.
    2. The petition for a second owner’s copy, the court order, and the certification were all fictitious.
    3. The deed of sale in favor of Flores was falsified.
    4. A prior Court of Appeals decision had already cancelled Arambulo’s title in favor of Dr. Rosalinda Z. Tiongco, but this decision was never enforced.

Court of Appeals Decision:

  • The Court of Appeals upheld the trial court’s findings regarding the falsity of the court order and certification.
  • However, it ruled that the deed of sale was valid, based on its notarization and the presumption of regularity.

Issue:

  1. Whether the deed of sale executed by Arambulo in favor of Flores was genuine or forged.
  2. Whether the Court of Appeals erred in upholding the validity of the deed of sale despite evidence of falsification.
  3. Whether the trial court’s findings on the falsity of the documents should prevail over the Court of Appeals’ decision.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Dispositive Portion

  1. The deed of absolute sale purportedly executed by Arambulo in favor of Flores is declared null and void.
  2. The Register of Deeds of Nueva Ecija is ordered to cancel TCT No. NT-187175 in Flores’ name and issue a new title in favor of Arambulo.
  3. Flores is ordered to surrender the second owner’s copy of TCT No. NT-187175 for cancellation.


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