G.R. No. L-69027 May 29, 1987
NARCISO R. LACUNA and FELISA P. LACUNA, petitioners, vs. THE HONORABLE INTERMEDIATE APPELLATE COURT and CEFERINA S. ARGALLON, respondents.

FACTS

Petitioner Narciso Lacuna was criminally prosecuted for falsely selling his rights to a house and lot to private respondent Ceferina Argallon for P5,000.00. The Court of First Instance acquitted him, expressly finding that the fact from which civil liability might arise did not exist. Argallon subsequently filed a civil case against Narciso and his wife, Felisa. The trial court absolved the spouses, relying on the criminal court’s finding of no causative fact for liability. The Intermediate Appellate Court initially affirmed this judgment.
However, upon Argallon’s Motion for Reconsideration, the IAC reversed itself. It held the Lacuna spouses civilly liable based on a receipt signed by Narciso acknowledging receipt of P5,000.00 from Argallon as payment for the right to the property. The Lacunas filed the instant petition after their motion for reconsideration of this reversal was denied.

ISSUE

Whether the Intermediate Appellate Court erred in reversing its initial decision and in holding the petitioners civilly liable based on the disputed receipt.

RULING

The Supreme Court granted the petition and set aside the IAC’s reversing resolution. While factual findings of the IAC are generally binding, an exception exists when there are erroneous inferences made from established facts. The Court found such erroneous inferences here.
The receipt, by itself, could not be considered the equivalent of a deed of sale for real property. The alleged price, though substantial for its time, was inadequate for a house and lot in Quezon City, and a businesswoman like Argallon would not have accepted a mere receipt for such a transaction. The receipt was legally insufficient for registration. Crucially, evidence indicated the receipt was simulated to accommodate Argallon, allowing her to pretend to a business associate that she had purchased a storage facility. Testimony revealed inconsistencies, such as the crossed-out “San Juan, Rizal” on the receipt and conflicting accounts of where it was issued, with one claim involving a bank on a Sunday—a non-banking day. The unrebutted allegation of a past live-in relationship between Narciso and Argallon further explained why he would accommodate her with a simulated document.
Therefore, the Supreme Court reinstated the IAC’s original decision affirming the trial court’s judgment, which had absolved the petitioners of civil liability, consistent with the prior criminal acquittal based on the non-existence of the foundational fact for such liability.