Case Summary (G.R. No. 237465)
Course of the Case
On September 1, 2011, the Spouses Coronel filed a complaint seeking annulment of deeds, cancellation of TCT No. 335024, recovery of possession, reconveyance, an injunction, and damages against Quesada. The Spouses Coronel claimed ownership of the subject property but alleged that their title was fraudulently transferred without their consent through a Deed of Donation executed by Catalina Hernando and subsequent dealings by her granddaughter, Mina M. Delos Reyes.
Chronology of Events
The case details that the Spouses Coronel allowed Catalina to manage the property in 1981, and upon Catalina's passing, Delos Reyes allegedly mortgaged the property without their consent. The Spouses Coronel discovered the donation and subsequent transactions only in 2005, well after titles were transferred first to Delos Reyes and then to Quesada. Furthermore, they contended that Delos Reyes and Quesada colluded to facilitate this transfer.
Trial Court Proceedings
The Regional Trial Court (RTC) granted a Motion to Dismiss filed by Quesada on April 28, 2014, citing both prescription of action and insufficiency of evidence to support the Spouses Coronel's claims. The RTC held that more than ten years had elapsed since the donation in 1995, and there was a lack of evidence establishing their possession and the circumstances surrounding their claim of ownership.
Court of Appeals Decision
The Court of Appeals (CA), in its decision dated July 11, 2017, affirmed the RTC’s rulings, emphasizing that the Spouses Coronel had not established the necessary elements to support their claims against Quesada, including failure to prove forgery of signatures and ownership rights. The CA found that the Spouses Coronel's self-serving assertions were inadequate in discrediting Quesada's title.
Arguments Presented by Petitioners
The Spouses Coronel's arguments focused on asserting that their title had been fraudulently transferred due to forged documents, which would render the transfer void. They questioned Quesada's good faith as a purchaser by emphasizing her close relationship with Delos Reyes, which they argued implied her knowledge of the potential fraud.
Analysis of Forgery Claims
The Court determined that the issue of forgery was fact-intensive and required strong evidence, which the Spouses Coronel failed to provide. Mere denial was insufficient to displace the presumption of regularity attached to notarized documents. The petitioners did not present expert evidence or adequately compare the alleged forged signatures to authentic ones, which rendered their claims unsubstantiated.
Legal Framework on Reconveyance
The action for reconveyance is rooted in provisions under Presidential Decree No. 1529 and relevant Civil Code articles. Su
...continue readingCase Syllabus (G.R. No. 237465)
Introduction
- The case involves a petition for review on certiorari filed by Spouses Asuncion Malig-Coronel and Reynaldo Coronel against Corazon Solis-Quesada.
- It originated from a complaint filed by the Spouses Coronel seeking annulment of deeds, cancellation of Transfer Certificate of Title (TCT) No. 335024, recovery of possession, reconveyance, and damages.
- The complaint was filed on September 1, 2011, in relation to a property located in San Vicente, Sta. Ignacia, Tarlac City.
Background of the Case
- The Spouses Coronel claimed ownership of Lot 9747-C, covered by TCT No. 156304, having permitted Asuncion's aunt, Catalina Hernando, to build a house on the property in 1981, while they managed their business in Pampanga.
- Catalina was entrusted with the property documents, and upon her illness, her granddaughter, Mina M. Delos Reyes, allegedly mortgaged the property without the Spouses' consent.
- In 2005, the Spouses discovered that a Deed of Donation had been filed, transferring the property to Delos Reyes, which led to the issuance of TCT No. 292249 in her name and subsequent sale to Quesada.
Allegations of Fraud and Collusion
- The Spouses Coronel denied ever executing the Deed of Donation, asserting it was falsified, and claimed that the June 16, 2000, Deed of Absolute Sale was also forged as Rodrigo A. Rodrigo was in Hawaii at the time of the transaction.
- They accused Delos Reyes and Quesada of colluding to transfer the property title.