G.R. No. 116602-03 - Sarao vs. Court of Appeals

The petitioner was originally Epifania S. Dela Cruz, who was later substituted by her niece, Laureana V. Alberto, following her death on November 1, 1996.
The respondents are the spouses Eduardo C. Sison and Eufemia S. Sison.

Epifania is claimed to have executed a Deed of Absolute Sale on November 24, 1989, transferring her rice land in Salomague Sur, Bugallon, Pangasinan to the respondents.
The property had been registered in Eduardo C. Sison’s name without Epifania’s knowledge or consent as alleged in her 1992 discovery.
The deed was notarized before Notary Public Maximo V. Cuesta, Jr. and subsequently supported by a host of official documents.

Epifania asserted that she was tricked into signing the deed by Eduardo, who allegedly inserted the Deed of Absolute Sale among other documents pertaining to the sale of her residential property, house, and camarin to her foster child, Demetrio Sison.
The petitioner also raised issues regarding her alleged inability to read and understand the English language used in the deed, invoking Article 1332 of the Civil Code as support for her claim.
Epifania’s complaint noted inconsistencies, such as the use of two sets of residence certificates and questions concerning the rationale for selling her assets despite her financial stability.

The Regional Trial Court (RTC) of Lingayen, Pangasinan, Branch 38 rendered a decision on March 20, 1996, in favor of Epifania, declaring the deed of sale null and void and awarding her attorney’s fees, litigation expenses, and costs.
The respondents, dissatisfied with the trial court’s ruling, elevated the case on appeal.
The Court of Appeals reversed the RTC’s decision on April 20, 2004, declaring the deed of sale valid based on evidentiary presumptions and supporting documents.

The respondents produced a series of documents supporting the validity of the sale:

A notarized Deed of Absolute Sale and related affidavits (from both seller and buyer),
An Investigation Report by the Department of Agrarian Reform (DAR),
Certificates issued by the Provincial Agrarian Reform Officer (PARO) and authorized payment verifications for Capital Gains Tax,
Supporting evidence of continuous and open possession of the property, including affidavits from property caretakers and tax declaration documents.

The evidence demonstrated that official acts and procedures (such as the cancellation and reissuance of tax declarations and issuance of certificates) had been performed in connection with the transfer.

Despite petitioner’s allegations of her inability to read the document and being tricked into signing, her testimony contained contradictory statements regarding her awareness of the documents, specifically noting that she read one document (pertaining to the sale for her foster son) while allegedly misunderstanding the deed in Eduardo’s favor.
The comparison of the two deeds (one in favor of Demetrio and the other in favor of Eduardo) revealed clear distinctions, suggesting that any deliberate attempt to deceive would have required the documents to be identical or mirror images.
The notarized nature of the deed and the presumption of its due execution played a crucial role in countering the petitioner's claims.

The RTC had found in favor of Epifania based on the alleged trickery and inconsistencies, but its findings were reversed on appeal.
The Court of Appeals held that the presumption of due execution enjoyed by a notarized document could not be overcome merely by bare and unsupported allegations of fraud or trickery, especially when the documentary evidence was both varied and corroborative.

Whether the Deed of Absolute Sale dated November 24, 1989, executed by Epifania, is valid.
Whether the petitioner’s allegations of trickery and fraud—particularly her claims of being deceived into signing documents and her alleged inability to understand the English language—are sufficient to rebut the presumption of due execution of a notarized document.
Whether the evidentiary findings of the trial court, which supported the petitioner’s claim, should prevail over the comprehensive documentary evidence and subsequent rulings of the Court of Appeals.