GR 122973; (July, 2000) (Digest)
G.R. No. 122973 ; July 18, 2000
DIONISIO C. LADIGNON, petitioner, vs. COURT OF APPEALS and LUZVIMINDA C. DIMAUN, respondents.
FACTS
Private respondent Luzviminda Dimaun filed a complaint for the nullity of a Deed of Absolute Sale covering a parcel of land in Talayan, Quezon City, registered under her name. She alleged that petitioner Dionisio Ladignon, a lawyer and relative, facilitated the sale of her property to Litogo Company, Inc. Dimaun denied having signed the deed or receiving the P800,000.00 purchase price, claiming her signatures were forged. The Regional Trial Court dismissed her complaint, upholding the notarized deed as a public document and awarding damages to Ladignon.
On appeal, the Court of Appeals reversed the trial court. It found the Transfer Certificate of Title (TCT No. 383675) issued in Dimaun’s name to be highly questionable due to an unexplained issuance process. The appellate court concluded that no valid sale occurred, declared the deed null and void, ordered the cancellation of the title, and awarded damages to Dimaun. It also ordered Ladignon to return the purchase price to the corporate buyer.
ISSUE
The core issue is whether the Court of Appeals erred in reversing the trial court’s factual findings and in declaring the deed of sale null and void, including the ancillary issue of whether it acted without jurisdiction in ordering the cancellation of a Torrens title.
RULING
The Supreme Court granted the petition and reinstated the trial court’s decision. The Court held that the Court of Appeals committed reversible error. First, it improperly engaged in a collateral attack on Torrens Title No. 383675. Under Section 48 of P.D. No. 1529, a certificate of title cannot be collaterally attacked; its validity can only be challenged in a direct proceeding expressly instituted for that purpose. An action for nullity of conveyance is not the proper direct proceeding to annul a title.
Second, the Court found the appellate court’s factual conclusions unfounded. The notarized Deed of Absolute Sale enjoys the presumption of regularity and carries the evidentiary weight of a public document. To overcome this, Dimaun needed to present clear and convincing evidence of forgery, which she failed to do. The Court emphasized that the weakness of the plaintiff’s evidence does not automatically strengthen the defendant’s case, but here, Dimaun did not substantiate her claim of forgery. The Court of Appeals’ inference that no sale was executed merely from its doubts about the title’s issuance was an unwarranted stretch of logic not supported by the evidence on record.