Case Digest (G.R. No. 174445)
Facts:
Spouses William Guidangen and Mary Guidangen v. Devota B. Wooden, G.R. No. 174445, February 15, 2012, Supreme Court First Division, Del Castillo, J., writing for the Court. Petitioners are the Guidangens; respondent is Devota B. Wooden.On September 2, 1997, respondent filed a complaint in the Regional Trial Court (RTC), Branch 14, Lagawe, Ifugao (Civil Case No. 572) seeking to compel petitioners to execute a registrable document of conveyance of a two‑storey house (the “old house”) located in the PNP barracks in Lagawe, and to enjoin petitioners from entering or taking possession. Respondent alleged that sometime in 1994–1995 she and her then‑husband, Nestor Wooden, bought the old house from petitioners for P60,000, evidenced by a private document which respondent claimed petitioner Mary took when she processed Nestor’s PNP claims after his death in 1997.
Petitioners denied any sale or execution of a private document. They claimed ownership: they built and occupied the old house from 1982 to 1988, thereafter moved to a new house, and allowed Nestor and respondent to occupy the old house rent‑free in the latter part of 1995. Petitioners introduced tax declarations, tax receipts, and an electric service application in Mary’s name as indicia of ownership; respondent relied on her testimony, testimony of two former tenants that they paid rent to her, and Nestor’s Statement of Assets, Liabilities and Net Worth (SALN) that listed a house.
The RTC, after trial, found that respondent failed to prove the sale by a preponderance of evidence and, in its January 28, 2004 Decision, dismissed the complaint and declared petitioners the owners of the house. On appeal, the Court of Appeals (CA) reversed in its June 15, 2006 Decision (CA‑G.R. CV No. 83209), concluding that respondent had established a right under Article 1357 of the Civil Code and ordering petitioners to execute the necessary document/s of sale in respondent’s favor; the CA denied petitioners’ motion for reconsideration in its September 1, 2006 Resolution.
Petitioners filed a Petition for Review on Certiorari under Rule 45 assailing the CA’s Decision and Resol...(Subscriber-Only)
Issues:
- Whether the Court of Appeals could validly order petitioners to execute a registrable document despite respondent’s failure to prove the due execution and existence of the alleged private document evidencing the purchase of the house.
- Whether the Court of Appeals could validly ignore or disregard the trial court’s assessment of witness credibility.
- Whether the Court of Appeals’ findings of fact are manifestly mistaken, without evidentiary basis, or contradictory to the trial court’s findings.
- Whether the alleged sale may be considered valid despite absence of evidence that William Guidangen consented to the alleged sale by Mary Guidangen.
- Whether the Court of Appeals erred in not recognizing the evidentiary weight of petitioners’ tax declara...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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