GR 200383; (March, 2018) (Digest)
G.R. No. 200383 . March 19, 2018
NORMA M. DIAMPOC, Petitioner, vs. JESSIE BUENAVENTURA and THE REGISTRY OF DEEDS FOR THE CITY OF TAGUIG, Respondents.
FACTS
Petitioner Norma Diampoc and her husband filed a complaint to annul a deed of sale and recover their title. They alleged they owned a parcel of land and that respondent Buenaventura, a friend, borrowed the owner’s duplicate certificate of title to secure a loan, promising to give them a portion of the proceeds and not to sell the property. They claimed that on July 2, 2000, Buenaventura made them sign a folded document without reading it, which they later discovered was a deed of sale conveying a one-half portion of their land to Buenaventura for ₱200,000. They asserted the deed was spurious, executed through fraud, and that they never received any consideration.
Buenaventura countered that the Diampocs had no cause of action, noting the case mirrored a previously dismissed estafa complaint. She presented the notarized deed of sale as evidence of a valid transaction. The Regional Trial Court dismissed the complaint, finding the Diampocs’ claim of fraud unsubstantiated. The Court of Appeals affirmed this decision.
ISSUE
Whether the deed of sale is null and void due to alleged fraud and deceit perpetrated by respondent Buenaventura.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The legal logic rests on the principles of contractual validity and the duty of a signatory to a document. A notarized deed of sale carries the presumption of regularity and is a public document that constitutes prima facie evidence of its authenticity and due execution. To overturn this presumption, the evidence must be clear, convincing, and more than merely preponderant.
The Court found the petitioners’ claim of fraud unproven. Their own admission that they signed the document without reading its contents constituted gross negligence. The law holds that a party who signs a document is presumed to have done so voluntarily and with full knowledge of its contents. If a person cannot read, it is their duty to have the document read to them. The petitioners’ failure to exercise this diligence estops them from later claiming ignorance of the deed’s contents. The Court emphasized that it cannot relieve parties from the consequences of their own unwise or negligent acts when they voluntarily entered into a formal contract. Absent clear proof of vitiated consent, the contract stands.