G.R. No. 130191 - Duterte vs. Sandiganbayan

The controversy involves a parcel of land and a commercial building originally owned by Jovita S. Pua.
Jovita S. Pua, the mother of siblings Myrna S. Pua and Pepito S. Pua, initially owned the property.
Although the land was placed in the name of Pepito S. Pua (the eldest son) through an exhibit (Exh. A), Jovita continued to exercise dominion by renting the property.

An amicable settlement in November 1980 resulted in the conveyance of 12 square meters of the land in favor of Arsenio Uy, reducing the unencumbered portion to 620 square meters.
Jovita S. Pua later intended to transfer the remaining lot to her daughter, Myrna S. Pua, whereby Pepito S. Pua and his wife Lourdes Uy executed a Deed of Donation in December 1989.
Subsequent transactions include the lease executed by Myrna S. Pua on April 3, 1992, and a separate promise to sell the property to Arsenio Uy and Rosita Uy for ₱1,200,000.00, with partial payment already received.

In connection with the sale, two deeds of absolute sale were executed in favor of Johnny P. Uy – one recorded on January 4, 1979 and another on January 10, 1990.
The deeds of sale were called into question since the 1979 deed allegedly contained a forged signature of a notary public (Atty. Valentin Remigio).
Handwriting examination by a PNP expert revealed that the signature on the contested document (Exh. 4-Uy) did not match the genuine signatures of notary public Remigio.

Registration issues arose with a reconstituted copy of TCT No. T-76755 allegedly issued based on a questionable order in an LRC petition.
A certified true copy of an alleged reconstitution order and related registration entries by the Register of Deeds were central to the discussions.
Testimony from various court clerks indicated discrepancies, including the non-existence or misfiling of certain petition dockets and orders.

The Regional Trial Court (RTC) of Cauayan, Isabela rendered a decision on January 31, 1995 declaring:

The Deed of Donation in favor of Myrna S. Pua valid and binding.
Both deeds of sale in favor of Johnny P. Uy as null and void.
The reconstituted TCT (T-76755) issued on questionable grounds null and void, with orders to reinstate the original title.
That Johnny P. Uy was declared the dummy of Leoncia Coloma, with recommendations for prosecuting parties under the Anti-Dummy Law.

The true vendee of the property was Leoncia Coloma and that the naming of the yet-to-be-born Johnny P. Uy followed Chinese tradition.
The 1979 Deed of Sale was executed with the intention merely to confirm the sale.
The registration practice (or defect thereof) and defect in notarization, if any, did not affect the substantive sale.

Evidence regarding the identity and capacity of the parties, including the legitimacy of Johnny P. Uy’s status and allegations of forged signatures in the deed of donation, were hotly disputed.
Contentions were also raised regarding the proper application of the law on agency and the Anti-Dummy Law.

Whether the respondent Court of Appeals erred in upholding that the 1979 and 1990 deeds of sale were null and void.
Considerations include:

Reliance on the testimony of a PNP handwriting expert.
The proper application of the principles of agency and representation, particularly regarding the naming of an unborn minor.
The factual matter of there having been an actual sale to petitioner Leoncia Coloma.
Allegations concerning the lack of legal capacity on the part of Johnny P. Uy.
Whether Leoncia Coloma is an innocent purchaser for value based on the title provided by the Register of Deeds.
The effect of the allegedly spurious reconstitution of the transfer certificate on the transfer of right.
The principle of double sale and its impact on the competing claims of rights.

Whether the respondent Court of Appeals erred in upholding the donation as valid and binding.
Specific issues include:

Whether the signature of the donor, Pepito S. Pua, was genuine.
Myrna S. Pua’s admission regarding the true ownership of the property by her mother, Jovita Pua.
The nature of the donation as mortis causa due to the continued leasing of the property, thus failing to meet testamentary formalities.

Johnny P. Uy was a dummy for Leoncia Coloma.
Petitioner Leoncia Coloma’s action, involving the use of the name of a minor, constitutes an evasion of the constitutional or legal requirements regarding Philippine citizenship.
The recommendation for prosecution under the Anti-Dummy Law was supportable, given that the parties involved were ultimately Filipino citizens.