G.R. No. 190057 . October 17, 2022.
SPOUSES ADOLFO B. VELARDE AND ANTONINA T. VELARDE, ET AL., PETITIONERS, VS. HEIRS OF CONCEPCION CANDARI, RESPONDENTS.

FACTS

The petitioners are the heirs of Isagani Velarde. They filed a complaint for quieting of title against respondent Concepcion Candari. Their claim was based on a notarized Deed of Sale with Right of Repurchase dated 1978, where Candari sold seven parcels of land to Isagani, and a subsequent notarized Deed of Quitclaim and Waiver of Rights dated 1986, executed after Candari failed to redeem the properties. Through these instruments, absolute ownership was conveyed to Isagani and the petitioners, with corresponding Original Certificates of Title (OCTs) and Tax Declarations (TDs) issued in their names. After Isagani’s death, Candari began acting as owner by instituting tenants and collecting rentals, prompting the suit.
Candari denied the validity of the deeds, claiming she merely entrusted the TDs to Isagani for tax payment and that the documents were procured through fraud. She asserted continuous ownership and possession since inheriting the lands. The Regional Trial Court (RTC) ruled in favor of the petitioners, declaring them the rightful owners. The Court of Appeals (CA) reversed the RTC, sustaining Candari’s allegations of fraud, declaring the deeds null and void, and ordering the petitioners to reconvey the properties and cancel their OCTs and TDs.

ISSUE

The core issue is whether the Court of Appeals erred in nullifying the notarized deeds and ordering reconveyance based solely on allegations of fraud, absent clear and convincing proof.

RULING

The Supreme Court granted the petition, reversed the CA Decision, and reinstated the RTC judgment. The Court emphasized the fundamental principle that a duly notarized instrument enjoys the presumption of regularity and validity. The burden to overturn this presumption lies with the party challenging the document, who must prove the alleged vitiating circumstance, such as fraud, by clear and convincing evidence. Mere allegations are insufficient.
The Court found that Candari failed to discharge this heavy burden. Her claim of entrusting the TDs for safekeeping was uncorroborated and belied by the execution of the notarized Deed of Quitclaim, a formal document explicitly relinquishing her rights. Her self-serving denial could not overcome the presumption of validity attaching to the notarized deeds. Furthermore, the petitioners’ possession of OCTs and TDs issued by the State constituted strong evidence of ownership. An action for quieting of title is precisely meant to remove clouds, like Candari’s baseless claims, on such titled ownership. The CA erred in canceling the titles based on unsubstantiated allegations, as a Torrens title cannot be collaterally attacked in this manner. The Supreme Court thus upheld the petitioners’ ownership and ordered Candari to vacate the properties.