Case Summary (G.R. No. 225808)
Petitioner
Spouses Edgardo M. Aguinaldo and Nelia T. Torres-Aguinaldo: they seek annulment of sale, cancellation of title, and damages, alleging fraud in the purported 1979 deed of sale transferring their lots to respondent.
Respondent
Artemio T. Torres, Jr.: he denies involvement in the 1979 deed, asserts a valid purchase by a 1991 deed of sale, pleads estoppel and prescription, and counterclaims for moral damages and attorney’s fees.
Key Dates
- July 21, 1979: date of the first Deed of Absolute Sale
- March 10, 1991: date of the second Deed of Absolute Sale
- March 3, 2003: complaint filed before the RTC
- January 21, 2010: RTC decision dismissing the complaint
- May 20, 2015: CA decision affirming the RTC and ordering execution of a registrable deed
- July 14, 2016: CA resolution denying reconsideration
- September 11, 2017: Supreme Court resolution
Applicable Law
- 1987 Philippine Constitution
- Civil Code Articles 1357 and 1358(1) (form of real property contracts)
- Property Registration Decree (P.D. No. 1529), Section 12 (notarization requirement)
- Rules of Court, Rule 132, Sections 20 and 22 (proof of private documents); Rule 39, Section 10(a) (enforcement of specific acts)
Facts
Petitioners discovered in December 2000 that three titles covering their lots had been issued to respondent under TCT Nos. T-305318 to T-305320, purportedly based on a July 21, 1979 deed of sale. They filed suit alleging that the 1979 deed was forged, that respondent acted in bad faith, and sought nullification of the deed, cancellation of the titles, and damages. Respondent answered, denied executing the 1979 deed, and maintained that a valid March 10, 1991 deed of sale transferred the properties to him. He invoked estoppel, prescription, and counterclaimed for moral damages and attorney’s fees.
RTC Proceedings
On respondent’s motion, the 1991 deed was examined by the NBI Questioned Documents Department, which concluded that petitioners’ signatures thereon were genuine. The RTC found petitioners failed to prove fraud by a preponderance of evidence, held the 1979 deed spurious, but recognized a valid sale by the 1991 deed, and dismissed the complaint.
CA Ruling
The Court of Appeals affirmed. It declared the 1979 deed spurious yet refused to nullify the corresponding titles. It upheld the validity of the 1991 deed based on: (a) the NBI reports and its own comparison of signatures; (b) petitioners’ admission of sale in Nelia’s November 12, 1998 letter; and (c) respondent’s tax payments from 1993 to 2003. Finding the 1991 deed improperly notarized (signatories were in Makati and the USA but нотарифиed in Tanza), it reduced the instrument to a private document. Nevertheless, to effectuate the validated sale, it ordered petitioners to execute a registrable deed of conveyance within thirty days from finality, under Civil Code Articles 1357 and 1358(1). Reconsideration was denied.
Issue
Whether the CA erred in ruling that respondent acquired the properties by the 1991 deed of sale and in directing petitioners to execute a registrable deed of conveyance in his favor.
Supreme Court Ruling
- The Court affirmed the CA’s finding that the 1979 deed of sale was forged and declared the related TCT Nos. T-305318, T-305319, and T-305320 null and void, noting that a forged deed conveys no title.
- It agreed that the 1991 deed’s improper notarization deprived it of public document status, making it a private instrument. Under Rules of Court, Rule 132, Sections 20 and 22, the genuineness of petitioners’ signatures was satisfactorily established by the NBI and the CA’s independent comparison. Petitioners failed to produce clear, positive, and convincing evidence of forgery. Their own declaration and absence of corroborating proof were insufficient to overcome the presumption of authenticity.
- Despite its unregistrable form, the sale’s validity was firmly established. The compulsory notarization requirement is a coercive means to ensure formality but does not invalidate the contract itself. The Court endo
Case Syllabus (G.R. No. 225808)
Parties
- Petitioners: Spouses Edgardo M. Aguinaldo and Nelia T. Torres-Aguinaldo.
- Respondent: Artemio T. Torres, Jr., substituted by his heirs Artemio L. Torres III, Emiko Nakajima Torres, Michael Melvin L. Torres, Reedah Chigusa N. Torres, and Ritz Emi N. Torres.
Facts
- Petitioners are registered owners of three lots in Tanza, Cavite under TCT Nos. T-93596, T-87764, and T-87765.
- In December 2000 they discovered that these titles had been transferred to respondent via a purported Deed of Absolute Sale dated July 21, 1979, resulting in TCT Nos. T-305318, T-305319, and T-305320.
- Respondent denied any involvement in the 1979 deed, asserting instead a valid Deed of Absolute Sale dated March 10, 1991, registered on March 26, 1991.
- Respondent pleaded estoppel and prescription, arguing petitioners’ suit—filed March 3, 2003—was barred by the four-year fraud prescription.
RTC Proceedings
- Petitioners filed their complaint for annulment of sale, cancellation of title, and damages before the RTC of Trece Martires City (Branch 23).
- The RTC ordered the NBI to examine the genuineness of signatures on the 1991 deed; NBI concluded that petitioners’ questioned signatures matched their sample signatures.
- In its January 21, 2010 Decision, the RTC dismissed petitioners’ complaint, finding the 1991 deed authentic and noting Nelia’s November 12, 1998 letter admitting the sale.
CA Proceedings
- Petitioners appealed to the Court of Appeals (CA-G.R. CV No. 96014).
- In its May 20, 2015 Decision, the CA:
- Declared the 1979 deed spurious, but
- Upheld a valid sale under the 1991 deed based on:
• NBI reports and CA’s independent examination of signatures,
• Nelia’s admission in her 1998 letter, a