Case Summary (G.R. No. 149750)
Parties’ Substantive Claims and Documentary Basis
Respondents asserted ownership over the subject parcel by inheritance from Hermoso de Leon’s father, Marcelino de Leon, through a Deed of Extrajudicial Partition. Respondents alleged that they had engaged the services of Atty. Florencio Juan in the early 1960s to handle their parents’ property documents. They claimed that Atty. Juan caused them to sign voluminous instruments, and that when certain documents later surfaced, many revealed conveyances by sale or quitclaim in favor of Hermoso’s brothers and sisters and in favor of Atty. Juan and his sisters, although, respondents maintained, no such conveyances were intended. Central to respondents’ theory was the claim that Hermoso de Leon’s signature on the Deed of Extrajudicial Partition with Quitclaim in favor of Rodolfo de Leon was forged. Respondents further alleged that Rodolfo de Leon later sold the land to petitioner, whereupon respondents demanded annulment of the document and reconveyance, but defendants refused.
Petitioner, in response, claimed that she acquired the land in good faith and for value on December 6, 1975, that she had maintained continuous, public, peaceful, and open possession, and that she had appropriated the produce of the land without objection.
Trial Court Proceedings: Laches and Presumption of Authenticity
On August 23, 1994, the Regional Trial Court (RTC), Branch 48, Urdaneta, Pangasinan, rendered judgment in favor of petitioner. The RTC held that respondents’ claim was barred by laches because more than eighteen years had passed since the land had been sold. It further ruled that because the instrument involved was a notarial document, the Deed of Extrajudicial Partition in favor of Rodolfo de Leon was presumptively authentic.
Court of Appeals Ruling: No Laches and No Conveyance from an Non-Owner
The Court of Appeals reversed the RTC. It held that laches did not bar respondents from pursuing their claim. It emphasized that laches is a doctrine in equity and cannot be used to resist enforcement of a legal right. The Court of Appeals also reasoned that at the time of the sale to petitioner, Rodolfo de Leon was not the owner, and thus could not transfer land rights petitioner could validly acquire. The Court of Appeals further declared that the signature of Hermoso de Leon on the Deed of Extrajudicial Partition and Quitclaim supporting petitioner’s claim was a forgery. Consequently, the appellate court held that petitioner could not be considered a buyer in good faith.
Issues Raised in the Supreme Court
Petitioner advanced four issues: first, whether the Deed of Absolute Sale dated December 6, 1975 was perfected and binding despite Rodolfo de Leon’s alleged non-ownership at the time of sale; second, whether the evidentiary weight of the Deed of Extrajudicial Partition with Quitclaim was overcome by more than a preponderance of evidence showing forgery; third, whether petitioner’s possession, including that of Rodolfo de Leon, was in good faith and could result in ownership by prescription; and fourth, whether respondents’ action filed on February 24, 1993 had prescribed and whether respondents were guilty of laches.
Legal Framework: Perfection of Sale and Transfer of Ownership
The Supreme Court began with the basic distinction under property and obligations law between the perfection of a contract of sale and the transfer of ownership. It held that a contract of sale is consensual and is perfected by mere consent, through a meeting of minds on the thing and the price. At perfection, the seller’s ownership is not an element necessary to form the contract. However, the contract creates an obligation on the seller to transfer ownership and deliver the determinate thing. The Court explained that ownership is acquired by the buyer only through tradition or delivery. Therefore, even if the contract is perfected, the transfer of the real right of ownership depends on delivery and, where the seller is not the owner at the time of delivery, on subsequent acquisition of title in accordance with Article 1434 of the Civil Code.
Applying this, the Court noted that at the time of the sale, Rodolfo de Leon was undisputedly not the owner of the land delivered to petitioner. Thus, the consummation of the contract and the consequent transfer of ownership hinged on whether Rodolfo de Leon subsequently acquired ownership under Article 1434. This required resolution of the authenticity and due execution of the Extrajudicial Partition and Quitclaim purportedly vesting the land in Rodolfo de Leon.
Authenticity of the Extrajudicial Partition and Quitclaim
On the second issue, petitioner argued that the Extrajudicial Partition and Quitclaim was authentic because it was notarized and executed according to law, and she maintained that there was no clear and convincing evidence to overturn the presumption of regularity attaching to a public document.
The Supreme Court rejected the argument. It reiterated that, as a general rule, the due execution and authenticity of a document must be reasonably established before it may be admitted in evidence. It recognized, however, that notarial documents may be presented without further proof because the certificate of acknowledgment constitutes prima facie evidence of execution. Still, the Court stressed that to contradict facts in a notarial document and to defeat the presumption of regularity, the evidence must be clear, convincing, and more than merely preponderant.
The Court of Appeals had found that Hermoso de Leon’s signature on the Extrajudicial Partition and Quitclaim was forged, a finding that conflicted with the RTC’s view. Ordinarily, the Supreme Court does not review factual issues. Yet it acknowledged an exception where the trial court and the Court of Appeals reach conflicting factual determinations. After reviewing the records, the Supreme Court found no reason to reverse the appellate court’s factual conclusion.
The Court examined the purported signature of Hermoso de Leon and compared it with other genuine signatures. It held that the purported signature in the Deed of Extrajudicial Partition and Quitclaim was a forgery, noting specifically that the variance could not be attributed to the document’s age or to mechanical acts. It also underscored that without corroborative testimony of attesting witnesses, the notary’s lone account regarding due execution was insufficient. The Supreme Court reasoned that the notary could hardly be expected to dispute the authenticity of the document he had notarized. Accordingly, the notary’s testimony required close scrutiny, which the Court of Appeals had found wanting.
Good Faith Possession and Prescription Against Registered Land
On the third issue, petitioner claimed that her possession was in good faith and that she could thereby acquire ownership by prescription. The Supreme Court held otherwise. It reiterated a settled rule: no title to registered land in derogation of that of the registered owner shall be acquired by prescription or adverse possession. It further stated that prescription could not run against the hereditary successors of the registered owner because they merely step into the decedent’s shoes and are a continuation of the predecessor’s personality.
Given that the land was covered by a certificate of registration, the Supreme Court concluded that the disputed land could not be acquired by prescription regardless of petitioner’s purported good faith.
Prescription of Action and Application of Laches
On the fourth issue, petitioner argued both that respondents’ right to recover ownership had prescribed and that respondents were guilty of laches. The Supreme Court
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Case Syllabus (G.R. No. 149750)
Parties and Posture
- AURORA ALCANTARA-DAUS filed a Petition for Review under Rule 45, Rules of Court seeking to set aside the Court of Appeals decision in CA-GR CV No. 47587.
- SPOUSES HERMOSO AND SOCORRO DE LEON sued for annulment of documents and reconveyance, ownership, possession, injunctions, and damages.
- The Regional Trial Court rendered judgment for petitioner on August 23, 1994, which the Court of Appeals reversed.
- The Supreme Court reviewed the conflict between the findings of the RTC and the CA and resolved the appeal on the merits.
Key Facts
- The disputed parcel is Lot No. 4786, Cadastral Survey of San Manuel, originally covered by Original Certificate of Title No. 22134 and later by Transfer Certificate of Title No. T-42238.
- Respondent Hermoso de Leon inherited the property from Marcelino de Leon by virtue of an extrajudicial partition among heirs.
- A deceased attorney, Florencio Juan, had custody of family documents and voluminous instruments surfaced after his death showing purported conveyances to various siblings and to Atty. Juan and his sisters.
- The Deed of Extrajudicial Partition with Quitclaim purportedly executed by Hermoso, Perlita, and Carlota in favor of Rodolfo de Leon was later claimed by respondents to contain Hermoso’s forged signature.
- Petitioner purchased the land from Rodolfo de Leon by a Deed of Absolute Sale dated December 6, 1975 and thereafter asserted continuous, open, and peaceful possession and appropriation of produce.
- Respondents filed their complaint on February 24, 1993 to annul documents and recover ownership.
Issues Presented
- Whether the Deed of Absolute Sale dated December 6, 1975 executed by Rodolfo de Leon in favor of petitioner was perfected and binding upon the parties.
- Whether the evidentiary weight of the Deed of Extrajudicial Partition with Quitclaim executed in favor of Rodolfo de Leon was overcome by more than a preponderance of evidence offered by respondents.
- Whether the possession of petitioner and her predecessor-in-interest, Rodolfo de Leon, over the land was in good faith.
- Whether the action filed by respondents on February 24, 1993 had prescribed and whether respondents were guilty of laches.
Trial and Appellate Rulings
- The RTC ruled in favor of petitioner, holding that respondents’ claim was barred by laches and that the notarial Deed of Extrajudicial Partition was presumptively authentic.
- The CA reversed the RTC, holding that laches did not bar respondents