G.R. No. 211687 - Spouses De Vera vs. Catungal

Parties and Subject Property
Vicente Catungal owned two parcels of unregistered land in Macabito, Calasiao, Pangasinan.
Upon his death on December 1, 1944, he was survived by five children, including Fausta and Genaro Catungal.

Deed of Extrajudicial Settlement with Absolute Sale
On July 23, 1994, Fausta (by thumbmark) and Genaro executed a Deed adjudicating the two parcels and selling them to spouses Eugenio de Vera and Rosalia Padilla for ₱30,000.00.
Fausta, being illiterate, affixed her thumbmark in lieu of signature; the Deed was notarized in the presence of Teodoro de Vera and Valentino de Vera.
New tax declarations were issued in the name of the spouses De Vera; Eugenio is a grandchild of Vicente and a compulsory heir.

Trial Court Proceedings
On July 23, 1997, Fausta filed a complaint before the RTC for nullity of documents, recovery of ownership, reconveyance, damages, and injunctive relief, alleging deceit, false pretenses, and misrepresentation in obtaining her thumbmark.
Fausta claimed the Deed did not reflect the true agreement, preterition of other heirs, lack of explanation of contents, absence of proper appearance before a notary, and her continued possession of the land.
The RTC denied petitioners’ motion to dismiss, granted a temporary restraining order, and later, on July 7, 2009, dismissed Fausta’s case for lack of proof of fraud.

Court of Appeals Decision
On September 26, 2013, the CA reversed the RTC, invoking the presumption of fraud or mistake under Article 1332 of the Civil Code due to Fausta’s illiteracy and the lack of proof that the Deed’s contents were explained to her.
The CA declared the Deed null and void, ordered restoration of the parcels to Fausta’s heirs, and awarded attorney’s fees of ₱30,000.00 and costs.
The CA denied the spouses’ motion for reconsideration on February 11, 2014.

Petition to the Supreme Court
Spouses De Vera raised errors in the CA’s factual findings, burden-shifting under Article 1332, and disregard of the Deed’s presumption of regularity.
Fausta’s heirs opposed, emphasizing Fausta’s illiteracy, absence of explanation, and failure of the spouses to produce the notary witness.

Main Issue
Whether Fausta freely and validly consented to the Deed of Extrajudicial Settlement Among Heirs with Absolute Sale.

Subsidiary Issue
Whether the presumption of fraud or mistake under Article 1332 of the Civil Code was properly applied and overcome.