Facts:

The case involves the appeal by Eustaquio Bael and Teofila Jumalon against the decision of the Intermediate Appellate Court, which had previously set aside a ruling from Branch III of the Court of First Instance of Dipolog City, Zamboanga del Norte. The controversy centers around a land parcel described as a portion of Lot No. 4620, covering an area of 3.3600 hectares located in Sto. Nino, Polanco, Zamboanga del Norte. The land originally belonged to Zoilo Bael, who inherited it from his parents. Upon his death on November 1, 1961, Zoilo’s surviving spouse, Eusebia Vda. de Bael, and their children, including Desiderio Bael, succeeded to the property and took possession of it.

On October 20, 1972, the heirs of Zoilo Bael filed a complaint alleging that Eustaquio Bael and Teofila Jumalon fraudulent obtained their rights over the land. They claimed that Desiderio Bael was misled into signing a Deed of Absolute Sale in January 1964, believing it was a mortgage for a loan of P200.00

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Facts:

Background of the Property Dispute

• The subject matter is a portion of Lot No. 4620, measuring 3.3600 hectares, located at Sto. Niño, Polanco, Zamboanga del Norte.
• Zoilo Bael inherited the land from his parents and, upon his death on November 1, 1961, his wife and children succeeded and took possession of the property.

Alleged Fraudulent Deed and Transaction

• In a complaint dated October 20, 1972, the heirs of Zoilo Bael (Eusebia Vda. de Bael, Renerio, Lerma, Conrado, Zosima, Maria, Emelita, and Desiderio) accused petitioners Eustaquio Bael and Teofila Jumalon of using deceit, fraud, and force.
• It is alleged that, in January 1964, under a false impression that he was executing a deed of mortgage to secure a loan of P200.00, one heir (Desiderio Bael) was induced to sign a document presented as a Deed of Absolute Sale for the disputed land for P1,500.00.
• The document:
• Was signed before a barangay captain and not before a notary public.
• Showed that the surviving wife, Eusebia Vda. de Bael, merely affixed her thumbmark rather than signing properly.
• The heirs further claimed that:
• No partition had been made among them, and neither Desiderio nor Eusebia was authorized by other co-heirs to encumber or sell the property.
• After the execution of the deed, petitioners took possession of the land by force and appropriated its produce, causing damage and prejudice to the heirs.

Defendants’ Position and Subsequent Litigation

• In their answer dated November 10, 1972, petitioners countered:
• The validity of the deed of sale, asserting that an oral partition existed among the heirs wherein, except for the minor heirs Lerma and Renerio, the remaining interests were sold to the petitioners.
• That Desiderio Bael signed and Eusebia Vda. de Bael affixed her thumbmark after receiving adequate consideration.
• That the document was properly acknowledged before a notary public and translated into the local Visayan Cebuano dialect.
• Affirmative defenses raised included:
• The insufficiency of the cause of action stated in the complaint.
• Bar of the action due to the statute of limitations.
• Counterclaim by petitioners sought damages and costs and prayed for the dismissal of the complaint.
• Trial court orders were rendered:
• An order directing petitioners to deliver the shares of the minor heirs (Lerma and Renerio) which had not been sold.
• A decision declaring the deed of sale and related private documents valid and legal, and awarding damages against some of the heirs.

Appellate Proceedings and Grounds of Appeal

• Both parties elevated the case first to the Intermediate Appellate Court, which reversed the trial court decision by:
• Declaring the public deed (Exhibit "1") and the private documents (Exhibits "2," "3," and "4") null and void.
• Recognizing the heirs of Zoilo Bael as the absolute owners of the property.
• Enabling a scheme for redemption upon payment by the heirs.
• Petitioners raised several errors in the Intermediate Appellate Court decision, notably:
• Error in holding that the documents did not authorize the sale of the shares of the other heirs.
• Error in attributing strict construction to private documents against petitioners.
• Error in failing to consider that action for annulment was barred by prescription.
• Error in not giving proper weight to the trial court’s factual findings.

Issue:

Prescription of the Action

• Whether the action for annulment of the transaction has prescribed under Article 1391 of the Civil Code, considering the lapses from the execution of the contested documents (1963–1964) to the filing of the case in 1972.

Admissibility and Evidentiary Value of the Documents

• Whether the public document (Exhibit "1") is admissible in evidence without needing further proof of due execution and proper acknowledgment, given its notarization.
• Whether the private documents (Exhibits "2," "3," and "4"), commonly known as "Salabutan," are admissible as evidence of sale, particularly since their genuineness and due execution were established by respondents’ conduct and corroborative testimonies.
• Whether the documents have been incorrectly characterized by the appellate court, in interpreting that they did not reflect the true intention of the parties and failed to meet the evidentiary requirements.

Weight of Trial Court Findings

• Whether the Intermediate Appellate Court erred in disturbing the trial court’s factual findings, especially with regard to the conduct of the parties, the possession and enjoyment of the property, and the witnesses’ testimonies evidencing actual transactions.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)