Case Digest (G.R. No. 225808)
Facts:
Spouses Edgardo M. Aguinaldo and Nelia T. Torres-Aguinaldo v. Artemio T. Torres, Jr., G.R. No. 225808, June 18, 2018, Supreme Court Second Division, Perlas-Bernabe, J., writing for the Court.Petitioners Spouses Edgardo M. Aguinaldo and Nelia T. Torres-Aguinaldo (petitioners) filed a complaint on March 3, 2003 for annulment of sale, cancellation of title, and damages against Artemio T. Torres, Jr. (respondent), alleging they were the registered owners of three lots in Tanza, Cavite (covered by certain TCTs) and that titles had been transferred to respondent by means of a purported Deed of Absolute Sale dated July 21, 1979 (the 1979 deed), which they claimed was executed by fraud and stealth and resulted in issuance of TCT Nos. T-305318, T-305319, and T-305320 to respondent.
Respondent denied participation in the execution of the 1979 deed and counterclaimed that the subject properties were validly sold to him by petitioners through a Deed of Absolute Sale dated March 10, 1991 (the 1991 deed). He asserted estoppel because petitioners had caused registration of the instrument and argued the action was prescribed. Petitioners maintained the 1991 deed was not executed by them, asserting they were in the United States when it was allegedly signed.
During trial, respondent moved to have the questioned 1991 deed examined by the NBI Questioned Documents Department, which reported that the signatures on the 1991 deed matched petitioners’ sample signatures. The Regional Trial Court (RTC), Branch 23, Trece Martires City, dismissed the complaint in a January 21, 2010 Decision, finding petitioners failed to prove forgery and that a valid sale to respondent existed, relying in part on Nelia’s November 12, 1998 letter admitting a sale.
Petitioners appealed to the Court of Appeals (CA). In a May 20, 2015 Decision, the CA affirmed the RTC’s dismissal of petitioners’ complaint but, while declaring the 1979 deed spurious on its own signature comparison, nevertheless found a valid sale to respondent based on (a) the NBI reports and the CA’s independent comparison sustaining the genuineness of petitioners’ signatures on the 1991 deed, (b) Nelia’s November 12, 1998 letter admitting the sale, and (c) respondent’s payment of real property taxes from 1993 to 2003. The CA observed the 1991 deed was improperly notarized (signatures made in Makati and the USA but notarization in Tanza), rendering it unregistrable, and therefore ordered petitioners to execute a registrable deed of conveyance in respondent’s favor within 30 days of finality pursuant to Articles 1357 and 1358(1) of the Civil Code. Petitioners’ motion for reconsideration was denied by CA resolution dated July 14, 201...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in ruling that a valid conveyance of the subject properties to respondent was established and in directing petitioners to execute a registrable deed of conveyance in respondent’s favor within thirty (30) days?
- Are the Deed of Absolute Sale dated July 21, 1979 and Transfer Certificates of Title Nos. T-305318, T-305319, and T-305320 null and...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)