GR 115734; (February, 2000) (Digest)
G.R. No. 115734 February 23, 2000
RUBEN LOYOLA, et al., petitioners, vs. THE HONORABLE COURT OF APPEALS, NIEVES ZARRAGA, et al., respondents.
FACTS
The dispute involves a parcel of land in Biñan, Laguna, originally co-owned by siblings Mariano and Gaudencia Zarraga. Upon Gaudencia’s death in 1983, petitioners, representing the heirs of her sisters Victorina and Cecilia, claimed a share in her estate. Private respondents, the children of Mariano, asserted ownership over the entire lot, claiming they purchased Gaudencia’s one-half share via a Deed of Absolute Sale dated August 24, 1980, for P34,000. This sale was executed while a prior case (G.R. No. 59529) involving the same property was pending before the Supreme Court. Based on this deed, TCT No. T-116067 was issued in the respondents’ names. Petitioners, as compulsory heirs of Gaudencia, filed an action to annul the sale and the title, alleging the contract was simulated or fictitious, as Gaudencia was already very old, illiterate, and had no independent legal advice during the transaction.
ISSUE
Whether the Deed of Absolute Sale dated August 24, 1980, is a simulated contract and therefore null and void.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision upholding the validity of the sale. The Court ruled that petitioners failed to present clear and convincing evidence to prove simulation of the contract. The burden of proof rests upon the party alleging simulation, and it must be established by clear and convincing evidence, not mere preponderance. The Court found the evidence presented—Gaudencia’s advanced age, alleged illiteracy, and the pendency of another case—insufficient to overturn the notarized document’s presumption of regularity and the specific factual findings of the Court of Appeals. The notarized deed carries the evidentiary weight of a public document, and the consideration, while potentially low, was not so grossly inadequate as to shock the conscience and prove simulation by itself. The Court emphasized that the assessment of the credibility of witnesses and evidence is best undertaken by the trial court and the Court of Appeals, and their concurrent findings are generally binding unless shown to be grounded on speculations. No such compelling reason was shown to warrant a reversal. Thus, the sale was declared valid and effective.