Title
Spouses William Guidangen and Mary Guidangen vs. Devota B. Wooden
Case
G.R. No. 174445
Decision Date
Feb 15, 2012
Respondent claimed ownership of a house through sale by petitioners, but failed to provide sufficient evidence. The trial court ruled in favor of petitioners, supported by strong ownership documentation. Court of Appeals reversed but was overturned in this ruling.
property dispute
contract of sale
evidence
A

Case Summary (G.R. No. 174445)

Factual Background

Respondent alleged that sometime in 1994 to 1995, she and her late husband Nestor Wooden, then a member of the PNP, bought from petitioners a two-storey “old house” located at the PNP Barracks for P60,000.00, evidenced by a private document of sale. She further alleged that petitioner Mary had taken that private instrument, together with other documents, when she processed claims and benefits due from the PNP of Nestor, who died in 1997. Respondent claimed that she and Nestor’s purchase entitled her to occupy the property and required petitioners to execute registrable documents of conveyance.

Petitioners denied the sale in categorical terms. They asserted that they had built the old house and had lived in it until 1988, after which they moved to a new residence. They also claimed that, since 1983, their nephew Nestor lived with them in both the old and new houses, and that they treated him as their own son. Petitioners maintained that after the couple married, they allowed respondent and Nestor to occupy the old house free of rent in the latter part of 1995, and that they even entrusted respondent and Nestor with the collection of rentals from tenants to cover maintenance and expenses for the house. To support ownership, petitioners presented tax declarations and tax payments in Mary’s name.

At trial, respondent testified on the alleged sale but admitted material gaps. She stated that she only saw and read the alleged private document; she was neither present during its execution nor a signatory; and she testified that the document was signed only by Mary. She also admitted that she was present only when the first installment was paid and that she gave Mary a house key for purposes of securing documents, but did not personally and actually see Mary enter the house. She testified that the first installment of approximately P16,000.00 or P16,500.00 was paid on August 19 or 20, 1994, while the balance of about P35,000.00 was paid sometime in December 1994 or 1995, after which a private writing was executed by Mary as a receipt of payment. Respondent characterized that receipt as the only evidence of the sale, which she claimed Mary had taken.

Respondent offered as witnesses former tenants, including PO3 Oscar Mamaclay and Policeman Jay Telan. They testified that they paid rentals to the Wooden spouses. Telan recounted that he initially paid rentals to Mary but was later advised by her to pay respondent because Mary claimed the house had already been sold to the Wooden spouses.

Mary’s testimony presented a different account. She asserted that she and her husband constructed the old house in the latter part of 1981 and occupied it from 1982 until 1988. She testified that after they left, the old house was leased, and in the latter part of 1995, they allowed the Wooden spouses to occupy the second floor for free. She claimed that the rental arrangements were intended for maintenance and minor repairs. Petitioners presented tax declarations and records, including a tax declaration first issued in Mary’s name as early as August 9, 1988, and tax receipts and clearance. Mary also testified about her application for electrical services with IFELCO, and she discussed her SALN entries for relevant years, which generally showed both the old and new houses, though not consistently in every year.

On respondent’s invocation of Nestor’s SALN, Mary denied participating in or assisting with the preparation of Nestor’s SALN and insisted that she became aware of the declaration of the house only when respondent filed the case. Mary’s testimony, however, also reflected inconsistencies. She admitted that the house declared in a duplicate copy of her own SALN for 1995 happened to be the new house rather than the old house, and she later explained discrepancies in values.

Petitioners’ witnesses included Gloria Linda Guinawa, the Municipal Assessor, who confirmed that the old house was first declared in Mary’s name and had not been declared in another person’s name, while also explaining that real property taxes may be paid years after assessment. Petitioners’ neighbor Erlinda Paraguas testified that she accompanied Mary to the old house after Nestor’s death and that Mary did not take documents from the house. Dolores Wooden, respondent’s mother-in-law, testified that Nestor renovated the old house for convenience but denied that he purchased it. Finally, SPO4 Florencio Kimmayong, as an administrative officer responsible for preparing Nestor’s SALN in 1996, testified on that administrative process.

RTC Proceedings and Decision

In its January 28, 2004 Decision, the RTC held that respondent failed to prove the alleged sale with the preponderance of evidence required to compel petitioners to execute conveyance documents. It dismissed the complaint and ruled that petitioners had shown unquestioned possession and ownership, warranting maintenance of the status quo. The RTC denied damages for lack of evidence.

CA Proceedings and Reversal

On appeal, the Court of Appeals (CA) reversed the RTC in its June 15, 2006 Decision, concluding that respondent had presented other “cogently strong proofs” that the trial court ignored. The CA reasoned that respondent had established a “thoroughly convincing case” for enforcement of the right contemplated in Article 1357 of the Civil Code, by clear preponderance of evidence, and ordered petitioners to execute, within fifteen (15) days from finality, the necessary registrable document/s of sale. The CA also authorized the trial court to execute the documents in petitioners’ stead if they failed or refused. Petitioners’ motion for reconsideration was denied in a September 1, 2006 Resolution.

Issues Raised in the Petition

Petitioners elevated the matter by a Petition for Review on Certiorari and argued, in substance, that the CA erred in: ordering execution of conveyance despite the absence of proof of due execution and existence of the private document of sale; disregarding or overriding the trial court’s credibility findings; concluding that the CA’s factual findings were supported by evidence rather than being manifestly mistaken; treating the alleged sale as valid even without proof of William’s consent to any act by Mary; and discounting petitioners’ tax declarations, tax payments, and electrical connections in their name. The core dispute centered on whether a contract of sale existed and was perfected so as to determine ownership.

Legal Basis and Supreme Court Reasoning

The Supreme Court granted the petition and reinstated the RTC decision, while acknowledging the general rule that appellate findings of fact bind the Court. It nevertheless examined the record because the trial court and the CA reached conflicting factual conclusions.

The Court emphasized the controlling burden of proof. Respondent, as plaintiff in a suit involving ownership of immovable property and seeking conveyance, had to rely on the strength of her own evidence, not on alleged weaknesses in petitioners’ claim. The Court found that respondent did not present the private document allegedly evidencing the sale. Although respondent insisted that Mary took the single and crucial receipt/document, the Court viewed this as uncorroborated accusation rather than proof of the document’s existence and taking. The Court reiterated that one who alleges a fact has the burden of proving it and that a mere allegation is not evidence.

Further, the Supreme Court held that respondent failed to establish the essential elements for a perfected contract of sale under Civil Code, Article 1475, particularly the meeting of the minds on the thing and the price. Respondent’s testimony regarding payments totaling P51,000.00 was described as unclear as to whether it represented the entire agreed purchase price or only part of the P60,000.00 alleged in the complaint. The Court also stressed the inability to ascertain due execution and authenticity of the private document because respondent was not present at execution and neither she nor her husband appeared as signatories. The Court found no supporting witness who knew about the private document or saw it executed.

The Supreme Court then addressed the CA’s “cogently strong proofs” and found them insufficient. The CA had relied on alleged renovations, collection of rentals, and the contents of SALN entries. The Supreme Court rejected the inference of ownership from these circumstances. It accepted Mary’s explanation that the Wooden spouses collected rentals only to fund maintenance and minor repairs and that renovations did not amount to dominion consistent with ownership. The renovations, according to petitioners’ evidence and respondent’s own omission, related only to the area occupied by the Wooden spouses—namely, the second floor—while the ground floor remained leased to tenants. The Court also noted that respondent’s own evidence did not mention renovation of the ground floor.

As to the CA’s speculation regarding Dolores Wooden’s testimony that Nestor denied ownership and the CA’s inference that Nestor must have bought the house after the visit, the Supreme Court ruled that such an assumption could not be used as a basis for judicial relief. It stressed that judgments must rest on facts, not conjectures and surmises.

On SALN, the Supreme Court found the CA’s reasoning speculative and incomplete. The Court noted that respondent did not offer in evidence Mary’s SALN that the CA relied upon, preventing verification of conclusions about what Mary knew or acquiesced in. The Court further rejected the CA’s premise that because Mary submitted Nestor’s 1996 SALN when Nestor was hospitalized and the SALN referred to only one property, Mary must have read it and acquiesced. The Supreme Court held that such inference depended on unproven factual assumptions—specifically, that Mary knew the contents and that the declared property corresponded to the exact old house subject of the case. The Court al

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