Case Digest (A.C. No. 7749) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Norma M. Diampoc v. Jessie Buenaventura and the Registry of Deeds for the City of Taguig, petitioner Norma M. Diampoc, with her husband Wilbur, claimed ownership of a 174-sqm parcel in Signal Village, Taguig City under TCT No. 25044. In July 2004, they filed before the RTC of Pasig City (Branch 268) Civil Case No. 70076 seeking annulment of a purported July 6, 2000 deed of sale of half their land to respondent Jessie Buenaventura, recovery of their duplicate title, and damages. They alleged Buenaventura borrowed their title as security for a P1 million loan, promised them P300,000, then induced them to sign a folded document without reading it, which later appeared as a sale of an 87-sqm portion for P200,000, notarized in their absence and secured by only one community tax certificate. The RTC dismissed their complaint for insufficiency of evidence, relying on the prima facie evidentiary force of a public document. The Court of Appeals (CA) in CA-G.R. CV No. 92453 affirmed th Case Digest (A.C. No. 7749) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ownership and Agreement
- Norma M. Diampoc and Wilbur L. Diampoc owned a 174-sqm parcel in Signal Village, Taguig City covered by Transfer Certificate of Title No. 25044.
- Jessie Buenaventura, their friend, borrowed the duplicate owner’s copy of TCT 25044 as security for her P1,000,000 bank loan, promising to give the Diampocs P300,000 from the proceeds and to repay the loan without selling the property.
- Discovery of Purported Deed and Procedural History
- On July 2, 2000 the Diampocs signed a folded document without reading its contents. They later learned that Buenaventura had annotated a deed of sale transferring half (87 sqm) of the property to herself for P200,000. Barangay conciliation failed, and they alleged fraud, filing in July 2004 a complaint for annulment of deed of sale, recovery of title duplicate, and damages before RTC Pasig (Civil Case No. 70076).
- The RTC, after trial, dismissed the complaint for insufficiency of evidence, ruling the notarized deed was a public document enjoying prima facie regularity. The Court of Appeals affirmed in February 2011, holding appellants failed to present clear and convincing evidence to overturn the deed. A motion for reconsideration was denied in May 2011. Petitioner then filed this Petition for Review on Certiorari before the Supreme Court.
Issues:
- Whether the Court of Appeals erred in applying the prima facie presumption of regularity to the notarized deed of sale despite alleged irregularities in its execution and notarization.
- Whether the Court of Appeals erred in ruling that a valid contract of sale existed between the parties.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)