Facts:

The case involves St. Mary's Farm, Inc. (petitioner) as the registered owner of a parcel of land measuring 25,598 square meters located in Bo. Pugad Lawin, Las Piñas City, under Transfer Certificate of Title No. S-1648 (11521-A). On June 27, 1988, the petitioner passed a board resolution authorizing Rodolfo A. Agana, Jr. (defendant), to cede 4,000 square meters of the property to T.S. Cruz Subdivision, following a final court decision in Civil Case No. 87-42915. However, after this transaction, Agana allegedly forged another board resolution claiming he was authorized to sell the remaining 21,598 square meters of the property. Subsequently, Agana entered into a deed of sale with Prima Real Properties, Inc. (respondent) on September 5, 1988, transferring ownership of the entire property. Following the sale, the original title was canceled, and a new title was issued in the name of Prima. The petitioner filed a complaint for annulment of the sale, alleging that the authoriz...

Facts:

Ownership and Initial Transaction

• St. Mary's Farm, Inc. (petitioner) was the registered owner of a 25,598-square-meter land in Las Piñas City under Transfer Certificate of Title (TCT) No. S-1648 (11521-A).
• In compliance with a court decision in Civil Case No. 87-42915, the petitioner authorized Rodolfo A. Agana, Jr. (respondent) to cede 4,000 square meters of the land to T.S. Cruz Subdivision on June 27, 1988.

Alleged Forgery and Subsequent Sale

• After the transaction, Rodolfo A. Agana allegedly forged a board resolution authorizing him to sell the remaining 21,598 square meters of the property.
• A series of transactions ensued between Rodolfo A. Agana and Prima Real Properties, Inc. (Prima), culminating in the execution of an absolute deed of sale on September 5, 1988, transferring ownership of the land to Prima.
• Prima subsequently purchased the 4,000-square-meter portion from T.S. Cruz Subdivision, leading to the cancellation of TCT No. S-1648 and the issuance of two new titles (TCT Nos. 7863 and 7864) in Prima's name.

Petitioner's Allegations

• The petitioner claimed that the board resolution authorizing Rodolfo A. Agana to sell the property was forged, and that Prima acted in bad faith by relying on the forged document without verifying its authenticity.
• The petitioner sought the annulment of the sale, reconveyance of the property, and damages against Prima, Rodolfo A. Agana, and the Register of Deeds of Las Piñas.

Defendants' Defense

• Prima argued that it acted in good faith, relying on the notarized board resolution and paying the full purchase price of PhP 2,567,760.00.
• Prima contended that it was a buyer in good faith and for value, and that the petitioner was estopped from seeking rescission of the sale after accepting part of the purchase price.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Presumption of Regularity of Notarized Documents: A notarized document carries the presumption of regularity, and a buyer is not required to inquire beyond the face of the document. Prima relied on the notarized board resolution and other supporting documents, making it a buyer in good faith.

2. Burden of Proof in Forgery Allegations: The burden of proving forgery lies with the party making the allegation. The petitioner failed to provide clear and convincing evidence to overcome the presumption of the authenticity of the notarized board resolution.

3. Estoppel by Acceptance of Benefits: A party cannot accept the benefits of a transaction and later seek to annul it. By accepting part of the purchase price, the petitioner was estopped from challenging the validity of the sale.

4. Finality of Factual Findings: The Supreme Court reiterated that it is not its function to re-examine factual findings of lower courts, especially when affirmed by the appellate court. Only questions of law may be raised in a petition for review under Rule 45.

Conclusion:

The Supreme Court upheld the validity of the sale, ruling that Prima was a buyer in good faith and for value, and that the petitioner was estopped from seeking annulment of the sale. The petition was denied, and the decision of the Court of Appeals was affirmed.