G.R. No. L-49430 - People vs. Lora y Vequizo

Respondent Braulio Katipunan, Jr. owned a 203-sqm lot with a five-door apartment at 385-F Matienza St., San Miguel, Manila, registered under TCT No. 109193.
The apartment units were leased to tenants generating rental income.

On December 29, 1985, Braulio, aided by his brother Miguel Katipunan (petitioner), executed a Deed of Absolute Sale for the property in favor of Edgardo Balguma and Leopoldo Balguma, Jr., represented by Atty. Leopoldo Balguma, Sr., for ₱187,000.00.
TCT No. 109193 was cancelled; TCT No. 168394 was issued in the Balguma brothers’ names. Beginning January 1986, Atty. Balguma collected rentals.

On March 10, 1987, Braulio filed Civil Case No. 87-39891 for annulment of the deed, alleging fraud, undue influence and lack of mental capacity (grade III education, low IQ). He claimed he never received the ₱187,000 consideration.
He twice moved to dismiss his own complaint—motions granted by the RTC—but the court later reinstated the case upon proof of his poor comprehension, as shown by the medical report of Dr. Revilla. The case was re-opened, and Agueda Katipunan-Savellano was appointed guardian ad litem for Braulio.

After trial, the RTC dismissed the annulment complaint, finding Braulio had knowledge of the transaction, received some loans, and voluntarily signed the deed.
On appeal, the Court of Appeals reversed and set aside the RTC decision, annulled the sale, declared TCT No. 168394 void, and ordered restoration of TCT No. 109193 in Braulio’s name.

Petitioners sought review before the Supreme Court, arguing the trial court’s factual findings—particularly on Braulio’s capacity and voluntariness—were entitled to full faith and credit and should not have been disturbed.

Whether the Court of Appeals erred in overturning the RTC’s factual findings on

Whether the Deed of Absolute Sale is voidable for vitiated consent (fraud, undue influence, incapacity) and thus annulable.