A.M. No. RTJ-02-1702 - Santos vs. Lorenzo

On April 7, 1988, Socorro Cabilao executed a notarized Deed of Absolute Sale covering a residential house and lot (TCT No. T-59) in favor of Ma. Lorna Q. Tampan, through her mother Antonieta, for a declared price of ₱10,000.00 (actual consideration ~₱100,000.00). The owner’s duplicate copy of the title was lost, prompting a petition for reissuance which was opposed by spouses Buyser.
Socorro disputed having sold the property and reacquired it, surrendering the owner’s duplicate back to her.

April 29, 1996 – Lorna and her attorney-in-fact filed Civil Case No. 4818 for nullity of the pacto de retro sale between Socorro and spouses Buyser.
May 5, 1996 – Socorro filed Civil Case No. 4826 for annulment of the Deed of Sale to Lorna, quieting of title, recovery of possession, injunction, and damages.

The RTC consolidated both cases, tried the consolidated actions, and on September 21, 2007:

Dismissed Case No. 4818 as moot after Socorro’s repurchase and return of the title duplicate.
Declared the Deed of Sale to Lorna null and void, citing indefeasible title, lack of Lorna’s personal signature or proof of authorization, grossly inadequate price, and suspicious timing of late registration.

A notarized deed of sale transfers ownership upon execution, regardless of registration.
Socorro failed to prove fraud or vitiation of consent; payment of realty taxes by the Tampans evidenced ownership.

The CA denied reconsideration on October 3, 2013. Socorro then filed the present petition for review on certiorari.

Whether the Deed of Absolute Sale between Socorro and Lorna is valid and binding despite (a) alleged fraud in obtaining Socorro’s signature, (b) gross inadequacy of the declared price, (c) non-registration for seven years, and (d) continued possession of the owner’s duplicate title by Socorro.