Case Summary (G.R. No. 205743)
Applicable Law
The resolution of the case is based on the provisions of the 1987 Philippine Constitution, the Civil Code of the Philippines regarding sales and property ownership, and relevant jurisprudence governing the validity of documents and agreements.
Facts of the Case
The conflict arose from the complaint filed by the heirs of Patrocinio Dayrit, who alleged that the deeds of sale executed in 1979 and 1991 in favor of Rosalinda Turla were invalid. They asserted that Patrocinio, the original owner of the properties, did not authorize such sales and claimed that his signature on the relevant documents was forged. They sought the nullification of the said deeds, the return of the properties, and damages.
Judicial Proceedings
The Regional Trial Court (RTC) rendered a decision favoring the heirs, declaring the contested deeds as null and void. The RTC found that there was sufficient evidence suggesting fraud in the conveyance of the properties to the Turla family. The court noted irregularities surrounding the deeds, including the lack of Patrocinio's wife Rita's consent, which was necessary for the sale of conjugal properties under the Civil Code.
Conversely, the Turla family argued that they had entered into a Conditional Sale with Patrocinio, complied with its terms, and later received ownership through a valid Deed of Absolute Sale. They claimed that any inconsistencies regarding signatures or documents stemmed from a third party, Josie Tanhueco, whom they entrusted with the transfer process.
Court of Appeals Review
Upon appeal to the Court of Appeals (CA), the lower court's ruling was affirmed. The CA highlighted the dubious nature of the deeds of sale as foundational to the cancellation of the original titles and asserted that the heirs had not adequately proven the payment for the properties as claimed.
Petitioners' Arguments
In the petition for review, the Turla family contended that the CA overlooked certain facts that could undermine its conclusions. They argued that the presumption of regularity should apply to the notarized documents, and asserted they had fulfilled their financial obligations under the Conditional Sale. The Turla family criticized the CA's ruling against their deed based on findings that they claimed were mere conjectures.
Respondents' Arguments
The heirs of Patrocinio countered, asserting that the irregularities surrounding the deeds warranted their nullification. They elucidated that the presumption of regularity in public documents is rebuttable by evidence of fraud or inauthenticity, and maintained that the existence of conflicting deeds further supported their position.
Supreme Court's Ruling
The Supreme Court, in a departure from the lower courts' conclusions, determined that the Deed of Absolute Sale executed on January 11, 1991, was valid despite the surrounding doubts. The Court noted that the transaction had been acknowledged by Patrocinio in the deed itself and that numerous receipts substantiated the payments made by the Turla family. It ruled that faults attributed to third parties in handling the property transfer process should not invalidate the legitimate salable inte
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Case Background
- Petitioners: Rosalinda Z. Turla and Spouses Ricardo and Myrna Turla.
- Respondents: Heirs of Patrocinio N. Dayrit, including Honorina Dayrit-Villanueva, Margarita Dayrit-Timbol, and others.
- Court: Supreme Court of the Philippines, Third Division.
- Case Reference: G.R. No. 205743, dated October 06, 2021.
- Nature of Petition: Petition for Review on Certiorari under Rule 45 of the Rules of Court.
Procedural History
- The initial ruling by the Regional Trial Court (RTC) of Angeles City, Branch 58, favored the respondents by declaring certain deeds of sale null and void and reinstating original titles.
- An appeal by the petitioners to the Court of Appeals (CA) was dismissed, affirming the RTC's decision.
- The petitioners then filed a petition for review to the Supreme Court, challenging the findings of fraud and the validity of the deeds.
Facts of the Case
- Patrocinio N. Dayrit owned two parcels of land in Angeles City, registered under TCT Nos. 40956 and 40967, and was married to Rita R. Mina.
- Patrocinio executed a Conditional Sale on November 11, 1983, with Ricardo Turla involving these properties.
- The Conditional Sale stipulated a purchase price of P317,000.00, with conditions for down payment and loan facilitation.
- Post Patrocinio's death in December 1991, his heirs discovered the cancellation of the original titles and the issuance of new titles in the name of Rosalinda Turla, based on alleged spurious deeds of sale from 1979 and 1991.
- The heirs filed a complaint for the declaration of nullity of the deeds and the titles, claiming forgery and failure of the Conditional Sale terms.
Rulings of the RTC
- The RTC ruled in favor of