Case Digest (G.R. No. 244076)
Facts:
Felix Chingkoe and Rosita Chingkoe v. Faustino Chingkoe and Gloria Chingkoe, G.R. No. 244076, March 16, 2022, Supreme Court Third Division, Lopez, M., J., writing for the Court.
The dispute concerns a parcel of land in Ayala Heights, Quezon City covered by TCT No. 8283, originally registered in the names of Faustino and Gloria Chingkoe (respondents). Faustino alleged that in 1990 he allowed his brother Felix (petitioner) to occupy the property and, at their mother Tan Po Chu’s request, signed an undated Deed of Sale which the mother kept to “appease” Felix.
Felix maintained he had possessed the property since 1989 and, on October 10, 1994, purchased the property from Faustino for P3,130,000.00; the parties executed a Deed of Sale before notary Atty. Reynaldo Z. Calabio, and Felix asserted he paid the full purchase price. Despite demands, Faustino refused to surrender the owner’s duplicate of TCT No. 8283, and Felix later learned the property had been mortgaged to RCBC. Felix filed a complaint for specific performance with damages to compel turnover of the TCT and effect transfer.
The Regional Trial Court (RTC), Branch 101, Quezon City, ruled for Felix in a Decision dated May 12, 2014, holding the notarized Deed of Absolute Sale existed and was duly executed; the RTC awarded P50,000 attorney’s fees and, upon partial reconsideration, ordered the defendants to surrender the owner’s duplicate (Order dated July 30, 2015). Faustino appealed to the Court of Appeals in CA-G.R. CV No. 106434. In its Decision dated April 30, 2018, the Court of Appeals reversed the RTC, crediting the testimony of Tan Po Chu that Faustino only signed the deed to appease Felix and concluding Felix failed to prove payment, thus rendering the contract void for lack of consideration. The CA denied reconsideration.
Petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court challenging the CA’s reversal, arguing the CA improperly set aside the RTC’s credibil...(Pro-only)
Issues:
- May the Supreme Court review the Court of Appeals’ factual findings where those findings are contrary to the findings of the trial court?
- Whether the notarized Deed of Absolute Sale is valid and binding — specifically, whether petitioners proved due execution and payment of the P3,130,000.00 purchase price.
- Whether petitioners are entitled to actual damages for unrealized profit...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)