Case Digest (G.R. No. 225808) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Edgardo M. Aguinaldo and Nelia T. Torres-Aguinaldo v. Artemio T. Torres, Jr. (G.R. No. 225808, June 18, 2018), petitioners filed on March 3, 2003 a complaint for annulment of sale, cancellation of title, and damages before the Regional Trial Court (RTC) of Trece Martires, Cavite, Branch 23. They alleged ownership of three lots in Tanza, Cavite, covered by TCT Nos. T-93596, T-87764, and T-87765, and claimed respondent fraudulently caused the execution of a Deed of Absolute Sale dated July 21, 1979, thereby securing TCT Nos. T-305318, T-305319, and T-305320. Respondent denied involvement in the 1979 deed and counterclaimed that petitioners validly sold the same properties to him under a Deed of Absolute Sale dated March 10, 1991, which he registered on March 26, 1991. He invoked estoppel and prescription. The RTC, after NBI examination of signatures, dismissed the complaint on January 21, 2010, finding the 1991 deed genuine, petitioner’s letter of November 12, 1998 admi Case Digest (G.R. No. 225808) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Properties
- Petitioners Spouses Edgardo M. Aguinaldo and Nelia T. Torres-Aguinaldo are registered owners of three lots in Tanza, Cavite covered by TCT Nos. T-93596, T-87764, and T-87765.
- Respondent Artemio T. Torres, Jr. holds TCT Nos. T-305318, T-305319, and T-305320 allegedly issued on the basis of a Deed of Absolute Sale dated July 21, 1979.
- Trial Court Proceedings
- In March 2003 petitioners filed a complaint for annulment of sale, cancellation of title, and damages, alleging the 1979 deed was spurious and obtained through fraud. Respondent counterclaimed, asserting a valid sale by a Deed of Absolute Sale dated March 10, 1991 and raising estoppel and prescription defenses.
- The RTC ordered an NBI handwriting examination, which found petitioners’ signatures on the 1991 deed genuine. In a January 21, 2010 Decision, the RTC dismissed the complaint for failure of proof, upheld the 1991 sale, and noted petitioners’ admission in a 1998 letter and respondent’s payment of real property taxes (1993–2003).
- Court of Appeals Proceedings
- In a May 20, 2015 Decision, the CA declared the 1979 deed spurious but nonetheless affirmed a valid sale via the 1991 deed based on the NBI reports, an independent signature comparison, Nelia’s 1998 admission, and tax payments.
- The CA found the 1991 deed improperly notarized (signed abroad yet notarized in Cavite), rendering it unregistrable, and directed petitioners to execute a registrable deed of conveyance within 30 days under Articles 1357 and 1358(1) of the Civil Code. A July 14, 2016 Resolution denied petitioners’ motion for reconsideration.
- Petition for Review
- Petitioners sought review of the CA Decisions before the Supreme Court, challenging the finding of a valid conveyance and the directive to execute a registrable deed.
- The central question became whether the CA committed reversible error in those rulings.
Issues:
- Whether the Court of Appeals erred in:
- Ruling there was a valid conveyance of the subject properties to respondent via the 1991 deed of sale; and
- Directing petitioners to execute a registrable deed of conveyance within thirty days from finality of the decision.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)