G.R. No. 163770; February 17, 2005
EPIFANIA DELA CRUZ, substituted by LAUREANA V. ALBERTO, petitioner, vs. SPS. EDUARDO C. SISON and EUFEMIA S. SISON, respondents.

FACTS

Epifania Dela Cruz filed a complaint to nullify a Deed of Absolute Sale dated November 24, 1989, covering her rice land, which was registered in the name of her nephew, Eduardo Sison. She alleged that Eduardo tricked her into signing the deed by inserting it among documents she was signing for the transfer of other properties to her foster child, Demetrio (Eduardo’s brother). She claimed she was 79 years old, unable to read English, and unaware of the sale. The respondents, spouses Eduardo and Eufemia Sison, denied fraud, asserting they purchased the property for P20,000. They presented the notarized deed and numerous supporting documents from the Department of Agrarian Reform, including clearances and affidavits, some bearing Epifania’s signature, to prove the sale’s legitimacy and their subsequent open possession.
The Regional Trial Court declared the deed invalid, finding that fraud attended its execution. The Court of Appeals reversed this decision, holding that Epifania’s bare allegation of trickery was insufficient to overcome the presumption of regularity accorded to the notarized document and the corroborative official records.

ISSUE

Whether the Deed of Absolute Sale dated November 24, 1989, is valid.

RULING

The Supreme Court affirmed the Court of Appeals and declared the deed valid. The Court held that the issue of fraud is factual, and while it may review conflicting lower court findings, the petitioner failed to provide clear and convincing evidence to overturn the appellate court’s conclusions. The Court found Epifania’s claim of illiteracy and deception inconsistent with her own complaint, wherein she stated she “read the document on top,” indicating an ability to read. Furthermore, Article 1332 of the Civil Code, which requires a party enforcing a contract to show that its terms were fully explained when the other party is unable to read, was not successfully invoked.
The respondents presented overwhelming documentary evidence—a notarized deed, DAR investigation reports, affidavits, clearances, and tax authorizations—which collectively proved the sale was regular and intentional. These varied official documents, many signed by Epifania herself, were too numerous to have all been procured by trickery. The Court emphasized the presumption that a notarized document is a public instrument and evidence of the facts therein. The petitioner’s uncorroborated testimony was insufficient to rebut this presumption and the corroborative evidence of the respondents’ open, continuous possession and the foster child’s admission of the sale. Thus, the Deed of Absolute Sale was upheld as valid.