G.R. No. 154609 - San Juan vs. Offril

Parties, property and relationships
Petitioner Maria Corazon San Juan (San Juan) — tenant of the first door of a five-door apartment built on a 264 square meter lot in Makati City formerly registered in the name of respondent Celeste M. Offril (Offril) under TCT No. (114181) S-24948.
Respondent Celeste M. Offril — registered owner of the 264 sqm lot; landlord of the apartment; died intestate on 22 May 1994 and was substituted by heirs in the proceedings.

Transactions and documents in dispute
Two deeds of sale dated 2 April 1979 and 14 June 1979 (purportedly conveying the unsegregated parcel) were later presented and, by virtue thereof, the property was subdivided into Lots 20-A to 20-F and separate TCTs were issued to San Juan for those lots.
A Deed of Partition executed on 2 May 1990 (and a Deed of Absolute Sale dated 2 April 1990) were introduced in the records; receipts and other payment documents were also presented by San Juan.
Chronology anomalies: the 1979-dated deeds were presented for registration only in 1990; some deeds were alleged to be antedated; Offril had earlier delivered her title to San Juan allegedly to enable San Juan to present it to a bank so Offril could obtain a loan.

Contentions of the parties
Offril’s claim: she never sold the property (the whole or the parts alleged); the 1979 deeds are spurious and her signatures were forged; she did not receive consideration; she discovered cancellation of her title and issuance of new TCTs through information from a city assessor’s office conveyed to her granddaughter.
San Juan’s claim: she validly acquired the property by sale evidenced by notarized deeds and receipts; she paid in cash and by checks encashed by Offril’s granddaughter as attorney-in-fact; the TCTs in her name enjoy presumption of validity; antedating was done to avoid tax and is immaterial to the gravamen that Offril executed the documents.

Trial court disposition and appellate progression
Trial Court (6 March 1996): found only Lots 20-A and 20-B were sold to San Juan; declared TCTs for 20-A and 20-B valid; declared the two deeds of sale dated 2 April 1979 and 14 June 1979 null and void; ordered cancellation of TCTs for Lots 20-C to 20-F and issuance of new titles to Offril; denied recovery of damages and costs to either party.
Court of Appeals (30 July 2002): affirmed the trial court in toto, finding Offril’s testimony credible, giving probative weight to the Deed of Partition, and concluding that Offril had rebutted the presumption of regularity of the challenged documents as to lots 20-C to 20-F.
Supreme Court: San Juan filed petition for review raising factual-appreciation and legal-contention errors; the petition was resolved by the Supreme Court decision under G.R. No. 154609.

Procedural posture and outcome at the Supreme Court
San Juan argued the CA erred in (a) finding no valid conveyance of all disputed properties, (b) concluding San Juan was estopped by the Deed of Partition, (c) holding the 1979 deeds spurious despite notarization and presumption of regularity, and (d) accepting Offril’s testimony despite alleged Alzheimer’s disease.
The Supreme Court reviewed the factual findings of the lower courts, considered documentary chronology and witness credibility, and reserved to the courts below determination of demeanor and credibility.

Questions of fact and evidence appreciation
Whether the trial court and Court of Appeals erred in finding that only Lots 20-A and 20-B were validly conveyed to San Juan and that the deeds purporting to convey Lots 20-C to 20-F were spurious.
Whether the Deed of Partition executed on 2 May 1990 operates to estop San Juan from claiming ownership of all lots and whether it rebuts her assertion of prior acquisition.

Questions of law on presumptions and burden of proof
Whether the presumption of regularity that attaches to notarized deeds and to Torrens titles/TCTs is conclusive in this instance or whether it was properly rebutted.
Whether the trial court improperly shifted the burden of proof to San Juan, or whether Offril sufficiently overcame the presumption of validity of the documents by clear and convincing evidence.
Whether Offril’s testimony should be discredited on the ground she allegedly suffered from Alzheimer’s disease and thus could not overcome the notarized deeds’ presumption.