G.R. No. 250980 - People vs. Caloring

Case Summary (G.R. No. 250980)

Petitioner’s Allegations and Trial Proceedings

Socorro contends she never sold the property to Lorna and that the purported deed is a simulated document procured by fraud under the guise of loan papers. After discovery of missing owner’s duplicate title, Socorro executed two pacto de retro sales—first to Enriqueta Baybayon (April 18, 1990) and later to spouses Buyser (January 25, 1995)—redeeming both. She sued for cancellation of the 1988 Deed of Sale (Civil Case No. 4826), while Lorna filed for nullity of the Buyser pact (Civil Case No. 4818). The Regional Trial Court consolidated the actions, heard testimony from parties and witnesses, and received documentary evidence including the notarized Deed of Sale, tax declarations, tax receipts, and owner’s duplicate title exhibits.

RTC Decision (September 21, 2007)

The RTC dismissed Lorna’s nullity suit (Case No. 4818) as moot after Socorro redeemed the property from spouses Buyser and recovered the title. It declared the 1988 Deed of Sale void for lack of Lorna’s personal signature, absence of proof of authority for her mother’s appearance, gross inadequacy of the declared consideration (PhP 10,000), and suspicious seven-year delay in registration. Socorro was confirmed as the lawful owner; possession was ordered returned to her.

CA Decision (January 31, 2013)

On appeal, the Court of Appeals held that a Torrens title’s indefeasibility does not prevent transfer of ownership by a duly executed deed of sale. The CA found Socorro failed to prove fraud or vitiated consent; the notarized Deed of Sale enjoys a presumption of due execution. Gross inadequacy of price and belated registration, absent fraud or mistake, do not invalidate a sale. The CA reversed the RTC’s annulment, dismissed Socorro’s complaint (Case No. 4826), and left the property in Lorna’s ownership.

Issue Before the Supreme Court

Whether the 1988 Deed of Absolute Sale transferring ownership of TCT No. T-59 from Socorro to Lorna is valid, considering allegations of fraud, illiteracy, inadequate price, and delayed registration.

Applicable Law

– 1987 Philippine Constitution (Property Rights).
– New Civil Code: Art. 1305 (elements of contract), Art. 1332 (fraud-on-illiterate party), Art. 1470 (inadequacy of price), Art. 1498 (effect of public instrument).
– Rules of Court, Rule 45 (scope of certiorari review).

Supreme Court’s Analysis of Evidence

Question of Fact and Standard of Review: The validity of the deed hinges on factual findings, generally not subject to Rule 45 review unless CA findings conflict with those of the RTC. Here, the SC evaluated such conflict and sided with the CA’s assessment.
Presumption of Regularity: A notarized public instrument carries prima facie presumption of authenticity and due execution. To overcome this, Socorro bore the burden of clear, convincing, and categorical evidence of fraud or mistake.
Alleged Fraud and Illiteracy: Socorro failed to prove illiteracy or inability to understand English. Her signature and participation in previous pacto de retro sales negated an assumption of ignorance. Article 1332’s presumption of fraud did not arise absent proof that terms were not explained. No purported loan documents wer