G.R. No. 112485 August 9, 2001
Emilia Manzano, petitioner, vs. Miguel Perez Sr., Leoncio Perez, Macario Perez, Florencio Perez, Nestor Perez, Miguel Perez Jr. and Gloria Perez, respondents.

FACTS

Petitioner Emilia Manzano filed a complaint seeking the annulment of two “Kasulatan ng Bilihang Tuluyan” (deeds of absolute sale) she executed in 1979 covering a residential house and lot in favor of her sister, Nieves Manzano. Manzano alleged the deeds were simulated; the true agreement was a commodatum or loan of the property to serve as collateral for a bank loan her sister intended to obtain. She claimed Nieves promised to return the property after loan payment. Nieves, her husband Miguel Perez Sr., and son Macario Perez subsequently mortgaged the property to secure a P30,000 loan. After Nieves died, her heirs (the respondents) refused to reconvey the property to Manzano despite the loan’s settlement.
The respondents countered that the transactions were genuine sales for valuable consideration, as clearly stated in the notarized deeds. They asserted ownership as Nieves’s heirs and argued that Manzano’s claim of a loan arrangement was unsupported. They also claimed an understanding existed for a possible resale to Manzano after the loan was paid, but they later decided against it. The trial court ruled for Manzano, declaring the deeds void and ordering reconveyance and damages. The Court of Appeals reversed this decision and dismissed the complaint.

ISSUE

Whether the Court of Appeals erred in reversing the trial court and in ruling that the evidence was insufficient to prove the deeds of sale were simulated and that the true contract was a commodatum.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle applied is that in civil cases, the party alleging a fact has the burden of proving it by a preponderance of evidence. The Court emphasized that oral testimony generally cannot prevail over the clear terms of a written agreement, especially a notarized document which carries the presumption of regularity. To contradict such a document, evidence must be clear, convincing, and more than merely preponderant.
The Court found Manzano’s evidence sorely lacking. Her claim rested primarily on her own testimony, which was self-serving and uncorroborated. The return of the mortgage documents to her by one respondent after loan payment was deemed an equivocal act insufficient to overturn the deeds. In contrast, the respondents presented the notarized deeds themselves, which on their face constituted absolute sales. The Court held that Manzano failed to present the requisite preponderance of evidence to substantiate her claim of simulation. Absent such proof, the explicit terms of the written contracts must govern. The decision underscores that courts decide based on evidence and legal logic, not on sympathy, and that ownership is determined by the strength of one’s own evidence, not the weakness of the opponent’s.