Case Summary (G.R. No. 154609)
Factual Background
San Juan, while trying to assist Offril with a loan application in 1990, convinced Offril to hand over the title to the property so she could present it to a bank. Subsequently, two purported deeds of sale, dated April 2 and June 14, 1979, were executed between Offril and San Juan. Offril claimed these deeds were forgeries and that she had neither sold the property nor received any consideration for it. Upon discovering that her title had been canceled and new titles had been issued in San Juan’s name, Offril sought to declare the deeds void.
Trial Court Proceedings
San Juan defended her position by asserting that she had legitimately acquired the property through valid sales, asserting that she paid cash and checks, which were encashed by Offril's granddaughter. In its decision on March 6, 1996, the trial court concluded that Offril sold only Lots 20-A and 20-B to San Juan and deemed those TCTs valid, despite dismissing the authenticity of the two earlier deeds of sale. The court found no clear evidence linking Offril to the spurious deeds, as at the time of their alleged signing, San Juan was not a lessee of Offril, contradicting her claims of ownership.
Appellate Court Ruling
Both parties initially appealed the trial court’s decision, but Offril later withdrew her appeal. San Juan argued that the trial court incorrectly shifted the burden of proof and overlooked the validity of the antedated sales. The Court of Appeals denied her appeal, affirming that Offril successfully proved fraud and forgery in the execution of the deeds, finding the authenticity of the Deed of Partition favorable to Offril.
Supreme Court Petition for Review
San Juan subsequently filed a petition for review with the Supreme Court, which focused on whether there was valid conveyance of the properties in question. She contended that there was no basis for finding a lack of valid transfer and asserted that her ownership was confirmed by TCTs, which bore presumption of validity. Additionally, San Juan claimed that Offril's inconsistent testimony diminished her credibility.
Analysis of Evidence and Credibility
The Supreme Court emphasized that the trial and appellate courts' findings of fact must be upheld unless completely devoid of support. Despite the notarized nature of the deeds, the Court acknowledged that notarization does not guaranteed validity and can be rebutted. The questionable timeline around the execution and registration of the documents raised significant doubts about th
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Case Overview
- This case is a petition for review regarding the Decision of the Court of Appeals dated July 30, 2002, which upheld the ruling of the Regional Trial Court of Makati City in Civil Case No. 92-3604.
- The parties involved are Ma. Corazon San Juan (petitioner) and Celeste M. Offril (respondent).
Factual Background
- Celeste M. Offril was the registered owner of a 264 square meter lot in Makati City, covered by Transfer Certificate of Title (TCT) No. (114181) S-24948.
- The property contained a five-door apartment leased to various tenants, including Ma. Corazon San Juan, who occupied the first door.
- In 1990, San Juan convinced Offril to temporarily deliver the title of the property for her loan application, which Offril believed was for her benefit.
- Without Offril’s knowledge, two deeds of sale were executed on April 2, 1979, and June 14, 1979, allegedly transferring ownership from Offril to San Juan.
- Offril claimed that these deeds were forged and that she had not received any consideration for the property.
Legal Claims
- Offril sought the nullification of the two deeds of sale and the cancellation of new TCTs issued to San Juan, asserting that the deeds were spurious.
- San Juan contended that she had validly acquired the property through genuine sales and that the alleged deeds of sale were legitimate