Case Digest (G.R. No. 132415)
Facts:
Miguel Katipunan, Inocencio Valdez, Edgardo Balguma and Leopoldo Balguma, Jr. v. Braulio Katipunan, Jr., G.R. No. 132415, January 30, 2002, Supreme Court Third Division, Sandoval‑Gutierrez, J., writing for the Court.The respondent, Braulio Katipunan, Jr., owned a 203‑square‑meter lot with a five‑door apartment at 385‑F Matienza St., San Miguel, Manila, registered under TCT No. 109193. On December 29, 1985, Braulio, assisted by his brother Miguel Katipunan (now petitioner), executed a Deed of Absolute Sale transferring the property to brothers Edgardo and Leopoldo Balguma, Jr., represented by their father Atty. Leopoldo Balguma, Sr. The original title was cancelled and TCT No. 168394 was issued in the Balgumas’ names; the Balguma brothers began collecting rentals in January 1986.
On March 10, 1987 Braulio filed a complaint for annulment of the Deed of Absolute Sale in the Regional Trial Court (RTC) of Manila, initially docketed in Branch 21 and later re‑raffled to Branch 28 as Civil Case No. 87‑39891. He alleged that Miguel, Atty. Balguma and Inocencio Valdez induced him to go abroad, procured falsified clearances, and by deceit and coercion caused him to sign a document he did not understand, which turned out to be a deed of sale; he also alleged he did not receive the stated consideration.
The defendants (now petitioners) denied the allegations and countered that Braulio knew the document’s contents, received payment, and had not objected while rentals were being collected. Braulio twice moved to dismiss his complaint (which were granted), but after motions for reconsideration and presentation of a psychiatric certificate showing Braulio’s poor comprehension, the trial court reinstated the case, appointed his sister Agueda Savellano guardian ad litem, set the case for pre‑trial, and thereafter dismissed the complaint on the ground that Braulio failed to prove his causes of action because he admitted executing the deed and receiving loans/payments.
On appeal, the Court of Appeals in CA‑GR CV No. 45928 (Decision dated July 31, 1997) reversed the RTC and annulled the Deed of Absolute Sale, giving weight to the psychiatric findings of Dr. Ana Marie Revilla that Braulio had very low IQ, was essentially illiterate, and could not comprehend English documents; the CA concluded his consent was vitiated and the sale voidable under Article 1390 of the Civil Code. The CA directed cancellation of TCT No. 168394 and restoration of TCT No. 109193.
Peti...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in overturning the RTC’s factual findings and credibility determinations?
- Should the Deed of Absolute Sale be annulled for want of valid consent (incapacity, undue influence or fraud), and what r...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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