G.R. No. 161074 - De Guia vs. Presiding Judge, Regional Trial Court Branch 12, Malolos, Bulacan

The subject matter involves a fishpond situated in Meycauayan, Bulacan, covered by TCT No. T-6358, comprising the A12 undivided portion owned by the late Primitiva Lejano Davis.
Petitioners—Fe Davis Maramba, Renato Davis, Flordeliza D. Yeh, Jocelyn D. Queblatin, and Betty Davis—are the heirs of Primitiva, while petitioner Manuel T. de Guia, acting for himself and as attorney-in-fact, claimed ownership after acquiring the property from his co-petitioners.

On August 8, 1973, Primitiva executed the Kasulatan ng Sanglaan (Exhibit "J"), a deed of mortgage in favor of respondents Spouses Teofilo R. Morte and Angelina C. Villarico, in consideration of a P20,000.00 loan.
On February 15, 1974, she executed the Kasunduan ng Bilihang Tuluyan (Exhibit "F"), a deed of sale conveying the subject property to respondents Spouses Ruperto and Milagros Villarico for P33,000.00.

On February 14, 1977, respondents Spouses Villarico executed a deed of sale (Exhibit "G") to sell back the property to Primitiva.
On March 26, 1977, Primitiva executed another deed of sale (Exhibit "H") selling the property again to respondents Spouses Villarico for P180,000.00.
On March 28, 1977, she executed another mortgage (Exhibit "I") in favor of respondents Spouses Morte for a loan amounting to P180,000.00.

Kasulatan ng Sanglaan (Exhibit "A") – Primitiva mortgaged the subject property to Spouses Morte for a loan of P500,000.00, with the document signed and witnessed by petitioner Renato.
General Power of Attorney (Exhibit "B") – Primitiva appointed respondents Spouses Villarico as her attorney-in-fact, authorizing them to lease, mortgage, or sell her property.
Kasulatan ng Pagpapabuwis ng Palaisdaan (Exhibit "C") – A lease contract for the property at an annual rental of P10,000.00, which also acknowledged an advance rental payment of P150,000.00 for fifteen years.
Pagpapawalang Saysay ng Kasulatan ng Sanglaan (Exhibit "D") – Executed by respondents Spouses Morte to cancel the earlier mortgage (Exhibit "I") on the subject property.
Pagpapawalang Saysay at Pagpapawalang Bisa ng mga Kasulatan (Exhibit "E") – Executed by Primitiva and respondents Spouses Villarico to cancel Exhibits "F", "G", and "H", on the ground that the amounts in those documents had been returned.

Petitioner Renato, an instrumental witness in the execution of these documents, testified that he read, understood, and attested to the contents of the deeds.
Notary Public Mamerto A. AbaAo confirmed that on the day of execution, money was actually given by respondents to Primitiva, substantiating the existence of valuable consideration.

In February 1986, petitioner De Guia, as attorney-in-fact for the co-petitioners, filed an Amended Complaint in the RTC of Malolos, Bulacan, seeking annulment of the mortgage (Exhibit "A") and the lease contract (Exhibit "C"), alleging that these were executed under threat and without valuable consideration.
The RTC, on February 28, 2002, ruled in favor of respondents by:

The Court of Appeals (CA) affirmed the RTC’s decision in its August 30, 2002 Decision and later denied petitioners’ motion for reconsideration on November 28, 2003.
Petitioners elevated the case to the Supreme Court through a petition for review on certiorari (G.R. No. 161074, March 22, 2010).

Petitioners argued that Exhibit "A" was simulated because Primitiva and petitioner Renato signed under the threat of immediate foreclosure, thereby vitiating their consent.
Petitioners also questioned the validity of Exhibit "C" on similar grounds.

They contended that the real estate mortgage for P500,000.00 and the lease contract were void against third persons (including petitioner De Guia) due to non-registration.

They raised issues regarding whether the CA’s decision to uphold the RTC ruling was erroneous, even though the matter raised was essentially factual in nature.

Whether the Court of Appeals erred in declaring the transactions—particularly the execution of Exhibit "A" (the Kasulatan ng Sanglaan) and Exhibit "C" (the lease contract)—as valid and not simulated.

Did the threat of foreclosure vitiate the consent of Primitiva and petitioner Renato, rendering the documents void?

Whether the non-registration of the mortgage and lease contract renders them void and not binding on third parties, including petitioner De Guia.
Whether the Supreme Court may review factual issues under a petition for review on certiorari, given that such issues are typically not within its purview as it is not the trier of facts.