G.R. No. 205743 - Turla vs. Heirs of Dayrit

The case originated from a complaint for the declaration of nullity of two Deeds of Sale (dated August 17, 1979 and January 11, 1991), cancellation of corresponding Transfer Certificates of Title (TCT Nos. 104129 and 104130), and damages filed by the heirs of Patrocinio N. Dayrit against petitioners Rosalinda Z. Turla and Spouses Ricardo and Myrna Turla before the Regional Trial Court (RTC) of Angeles City, Branch 58.
After the RTC ruled in favor of the respondents (heirs) on May 28, 2009, the petitioners appealed to the Court of Appeals (CA), which dismissed their appeal on August 31, 2012, and later denied their motion for reconsideration on January 31, 2013.
A Petition for Review on Certiorari under Rule 45 was subsequently filed challenging the CA’s and RTC’s rulings.

Patrocinio N. Dayrit was the registered owner of two parcels of land in Angeles City, covered by TCT Nos. 40956 and 40967, and married to Rita R. Mina.
During his lifetime, Patrocinio executed a Conditional Sale on November 11, 1983 with petitioner Ricardo Turla involving not only the two parcels but also a third property (TCT No. 47382), for a total purchase price of P317,000.00.
Under the Conditional Sale:

A down payment of P50,000.00 was stipulated, of which P20,000.00 had already been paid by Ricardo.
The remaining balance of P267,000.00 was to be paid upon the release of Ricardo’s loan from the Development Bank of the Philippines (DBP) or another banking institution.
It was agreed that if Ricardo failed to comply—whether by backing out, disapproval of his loan, or loss of interest—the partial down payment would be forfeited in Patrocinio’s favor.

To facilitate the bank loan, Patrocinio executed a Special Power of Attorney (SPA) in favor of Ricardo and his wife Myrna, which was duly annotated on the titles as Entry No. 1508.
A real estate mortgage was constituted on the two properties and later released in June 1996 (Entry No. 8087).

After Patrocinio’s death on December 16, 1991, respondents (the heirs) discovered that:

TCT No. 40956 had been cancelled and replaced by TCT No. 104129 in the name of Rosalinda Turla, and similarly, TCT No. 40967 was replaced by TCT No. 104130.
These cancellations appeared to be based on alleged Deeds of Absolute Sale executed in 1979 and 1991 between Patrocinio and Rosalinda.

They had no recollection of their father selling the properties or authorizing such transfers, alleging that Patrocinio’s signature in the disputed deed appeared forged.
They were only aware of the 1983 Conditional Sale, and contended that the conditions for full payment had not been fulfilled by petitioner Ricardo.

Their longstanding occupancy and familial relation with Patrocinio, having lived in the properties since the 1960s.
That negotiations culminated in the Conditional Sale, and subsequently, payments (evidenced by receipts) were made in partial fulfillment of the contract.

On January 11, 1991, Patrocinio received the remaining balance, and an Absolute Deed of Sale was executed, notarized before Atty. Eric V. Mendoza.
To settle the bank loan obligations, petitioners transferred ownership to Rosalinda, who later acted as the payor for the loan’s full release.

One purportedly in favor of Ricardo (notarized and supported by payment receipts) and another in favor of Rosalinda, the latter of which petitioners denied executing and attributed to the conduct of Josie Tanhueco, a third party engaged to facilitate title transfers.

Rosalinda testified that she was unaware of the execution of the disputed deed in her favor, as similarly testified by Ricardo.
Petitioners contended that the notarized Absolute Deed of Sale dated January 11, 1991 in favor of Ricardo serves as conclusive evidence of full payment and effective transfer of ownership, as it was executed as a perfected public instrument.
The respondents, however, relied on the presentation of conflicting documents and alleged forged signatures to assert that fraud was committed in the transfer of ownership.

Whether the alleged Deeds of Sale (dating to 1979 and 1991 in favor of Rosalinda) were executed legally or were spurious.
Whether the payment evidence provided, including the Conditional Sale and the notarized Absolute Deed of Sale in favor of Ricardo, sufficed to satisfy the contractual obligations.
The extent of the applicability of the presumption of regularity for public documents and the responsibility to prove forgery or fraud.

Whether the Court of Appeals committed grave abuse of discretion by declaring that the rule on the presumption of regularity in the execution of public documents could not be invoked.
Whether the CA erred in disregarding the de facto existence and binding character of the Conditional Sale executed on November 11, 1983, especially given its subsequent ratification by Patrocinio’s wife.

Whether the CA failed to give sufficient weight to the Absolute Deed of Sale dated January 11, 1991, which petitioners argued served as evidence of full payment and consummated the transfer of title.
Whether the alleged payment receipts and other documentary evidence sufficiently established compliance with the terms of the Conditional Sale’s payment obligation.

Whether the existence of two conflicting Deeds of Sale (one in favor of Ricardo and one in favor of Rosalinda) suggests fraud and, if so, which transaction accurately reflects the true intention of the parties.
Whether the transfer of title without the explicit consent of Patrocinio’s wife (as required by Article 166 of the Civil Code) renders the sale void or merely voidable.