G.R. No. 146678; September 29, 2004
SPOUSES FELIPE R. ANGELES and GREGORIA ANGELES, petitioners, vs. SPOUSES FERMIN TAN and TERESITA TAN, IRENEO TAN and TERESA SO, MARIANO TAN and CORAZON CO, and HON. GEORGE MACLI-ING, Presiding Judge, RTC, Branch 100, Quezon City, respondents.

FACTS

Petitioners, the Angeles spouses, were the registered owners of a parcel of land. In 1969, they mortgaged a portion of this land to Prudencio Reyes to secure a loan. They claimed that after fully paying this loan in 1978, they obtained another loan from respondent Fermin Tan. They voluntarily delivered their owner’s duplicate certificate of title to Tan based on a verbal agreement for its return upon payment. They also entered into a joint business venture on the property. Petitioners alleged that by 1985, unpaid rentals from Tan for the use of the property had offset their loan, so they sought to liquidate the venture. They were then informed by Tan’s counsel that the property had been transferred to Tan’s name.
Respondents presented a different chain of title. They asserted that after petitioners defaulted, Reyes extrajudicially foreclosed the mortgage in 1977, consolidated ownership, and obtained a new title. Reyes then sold the property to the Tan respondents via a Deed of Absolute Sale in 1978, after which a new title was issued in their names. Petitioners filed a complaint for reconveyance with damages, alleging fraud. The trial court eventually dismissed the complaint and the respondents’ counterclaim. The Court of Appeals affirmed the dismissal.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaint for reconveyance and in not remanding the case for further proceedings.

RULING

The Supreme Court denied the petition and affirmed the dismissal. The legal logic centers on the burden of proof and the evidentiary weight of official records. Petitioners, as plaintiffs in a suit for reconveyance based on fraud, carried the burden of proving their allegations by clear and convincing evidence. They failed to discharge this burden. The Court found that a full trial on the merits had already been conducted, and petitioners did not identify any specific, material evidence they were prevented from presenting.
Critically, respondents anchored their ownership on public instruments and official entries in the Register of Deeds, specifically the Deed of Absolute Sale and the subsequent Transfer Certificates of Title. Under Section 44, Rule 130 of the Revised Rules on Evidence, entries in official records made by a public officer in the performance of duty are prima facie evidence of the facts stated therein. In the absence of clear, competent, and convincing proof from petitioners to overcome this prima facie presumption and to establish the alleged fraud in the issuance of the titles, the documentary evidence of the respondents must prevail. The Court thus upheld the indefeasibility of the Torrens title and found no reversible error in the appellate court’s decision.