GR 146721; (September, 2006) (Digest)
G.R. No. 146721 September 15, 2006
MAURA PASCUAL, petitioner, vs. CONRADO FAJARDO, substituted by ANTONIO, CONRADO, JR., ALICIA, CORAZON, and LEONIDA, all surnamed FAJARDO and DANIEL T. GREGORIO, respondents.
FACTS
Petitioner Maura Pascual and respondent Conrado Fajardo cohabited without marriage from 1971 to 1991. In 1982, Fajardo validly purchased a parcel of land from Josefina Jacinto. In 1991, Fajardo discovered that Pascual had fabricated several deeds of sale dated 1978, which fraudulently transferred ownership of portions of the 1982-acquired property to herself. These documents, notarized by Atty. Primitivo Punzalan in Cabanatuan City, included a simulated 1978 sale from Jacinto to Fajardo and subsequent sales from Fajardo to Pascual. Pascual also caused the issuance of TCT No. 288789 in her name for a 3,000-square meter portion.
After Fajardo’s death, his legitimate children and witness Daniel Gregorio filed a complaint for nullification of the deeds, cancellation of the title, and damages. The trial court ruled in favor of the respondents, declaring all questioned documents void. It found the signatures forged, noted Atty. Punzalan’s dubious notarial authority as a government employee at the time, and highlighted the absence of notarial records. The Court of Appeals affirmed the trial court’s decision.
ISSUE
Whether the Supreme Court can review the factual findings of the lower courts which declared the subject deeds of sale null and void.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court emphasized that it is not a trier of facts. A petition for review under Rule 45 of the Rules of Court raises only questions of law, not factual issues. The petitioner failed to present any special or compelling reason to warrant an exception to this rule.
The factual findings of the trial court, as affirmed by the Court of Appeals, are binding and conclusive when supported by evidence. Here, the lower courts’ conclusions were based on clear evidence: the forgery of signatures, the questionable notarial acts of Atty. Punzalan who lacked proper authority and records, and the inherent impossibility of the 1978 deeds concerning a property acquired only in 1982. Since no cogent reason was shown to overturn these concurrent factual determinations, the Supreme Court upheld the nullification of the deeds, the cancellation of the title, and the award of damages in favor of the respondents.