GR 145017; (January, 2005) (Digest)
G.R. No. 145017; January 28, 2005
DR. JOSE and AIDA YASON, petitioners, vs. FAUSTINO ARCIAGA, FELIPE NERI ARCIAGA, DOMINGO ARCIAGA, and ROGELIO ARCIAGA, respondents.
FACTS
Spouses Emilio and Claudia Arciaga owned a parcel of land. On March 28, 1983, they executed a Deed of Conditional Sale over the property in favor of spouses Dr. Jose and Aida Yason for ₱265,000.00, with an initial payment of ₱150,000.00. Upon payment of the balance on April 19, 1983, a Deed of Absolute Sale was executed. Claudia Arciaga died later that same day. The petitioners entrusted the registration of the deed to Jesus Medina, who falsified it by altering the date to July 2, 1979 and reducing the price to ₱25,000.00. Based on this forged deed, a new title was issued to the Yasons, who subsequently subdivided and sold portions of the lot.
In 1989, four of the Arciaga children (respondents) discovered the falsification and filed a complaint for annulment of the remaining 13 titles in the petitioners’ names. They alleged the sale was void because Claudia was seriously ill and could not have consented, and that a forged deed conveys no title. The Regional Trial Court dismissed the complaint, upholding the validity of the sale. The Court of Appeals initially affirmed but, on reconsideration, reversed itself, declaring the Deed of Absolute Sale null and void.
ISSUE
Whether the Deed of Absolute Sale dated April 19, 1983 is valid, thereby vesting ownership of the property upon the petitioners.
RULING
The Supreme Court reversed the Amended Decision of the Court of Appeals and reinstated the RTC’s dismissal of the complaint, upholding the validity of the sale. The Court clarified that the action was for annulment of titles based on the alleged nullity of the contract of sale, not an action for reconveyance based on the falsified document. The core issue was the validity of the genuine April 19, 1983 Deed of Absolute Sale, not the forged July 2, 1979 document used for registration.
The Court found that all essential elements of a contract—consent, object, and cause—were present. Consent was established through the notarized Deeds of Conditional and Absolute Sale, which enjoy the presumption of regularity. The Court gave little weight to the appellate court’s reliance on minor inconsistencies in witness testimonies regarding the notarization venue, noting the long passage of time. Respondents failed to present strong, complete, and conclusive proof of Claudia Arciaga’s incapacity or lack of consent. Testimonies and circumstances indicated she was alert and participated in the sale. The subsequent forgery by Medina did not vitiate the consent already validly given in the authentic agreement. Therefore, the contract was valid and binding.