G.R. No. 227460 , December 05, 2019
PABLO UY, SUBSTITUTED BY HIS HEIRS, NAMELY: MYLENE D. UY, PAUL D. UY, AND PAMELA UY DACUMA, PETITIONERS, VS. HEIRS OF JULITA UY-RENALES, REPRESENTED BY: JESSICA R. ROSERO, JOSELITO RENALES AND JANET U. RENALES; JOVITO ROSERO AND MARILYN RENALES, RESPONDENTS.

FACTS

The case involves a dispute over Lot No. 43 and a building thereon in Catbalogan, Samar, originally registered under Transfer Certificate of Title No. T-1467 in the name of Eufronia Labnao. Labnao had two children: petitioner Pablo Uy and Julita Uy-Renales. Julita died in 1976, leaving her children, the respondents Heirs of Julita. Upon Labnao’s death in 1995, petitioner Uy claimed a one-half share in the property as co-owner with the respondents. He discovered a Deed of Absolute Sale dated April 11, 1990, purportedly executed by Labnao, selling the lot to the respondents. Petitioner Uy filed a complaint for Declaration of Nullity of the Deed of Sale, Reconveyance and Damages, alleging the signature of Labnao was a forgery, as supported by a PNP Crime Laboratory report. The respondents filed a separate action for Quieting of Title, asserting ownership based on the Deed of Absolute Sale and claiming the building was constructed by their mother Julita, making them its exclusive owners by inheritance. The Regional Trial Court (RTC) consolidated the cases and ruled in favor of the respondents, declaring them owners of the lot and ordering them to pay petitioner Uy the present value of one-half of the building. The Court of Appeals affirmed the RTC decision. Petitioner Uy appealed to the Supreme Court.

ISSUE

Whether there was a valid contract of sale entered into between Labnao and the respondents Heirs of Julita, transferring ownership of the subject lot.

RULING

No. The Supreme Court reversed the decisions of the lower courts. The Court found the Deed of Absolute Sale void. The notarization was defective because the notary public, Atty. Jose Mendiola, admitted he did not personally witness Labnao sign the document and did not ascertain her identity, violating notarial law requirements. Consequently, the deed did not enjoy the presumption of regularity and was not a public document. The respondents failed to prove the due execution and authenticity of the deed. Furthermore, the respondents’ own witness, Dionito Aban, who was listed as an instrumental witness, testified he did not see Labnao sign and was merely asked to sign as a witness afterward. The Court also noted that the consideration in the deed was grossly inadequate (P15,000 for a 198-square meter lot in the town center), indicating the absence of a true sale. Therefore, no valid contract of sale existed. The lot remained part of Labnao’s estate to be inherited in equal shares by petitioner Uy and the respondents Heirs of Julita. The building, having been built during Labnao’s lifetime with contributions from petitioner Uy, also formed part of her estate. The case was remanded to the RTC for proceedings on the partition of the estate of Eufronia Labnao.