G.R. No. 215614 March 27, 2019
Carmelita V. Dizon, Petitioner vs. Jose Luis K. Matti, Jr., Respondent

FACTS

Respondent Jose Luis K. Matti, Jr. filed a Complaint for Specific Performance against petitioner Carmelita V. Dizon. Matti alleged that in February 2000, through real estate agents, he inspected a townhouse owned by Dizon, verified the original title with the Register of Deeds (RD), and subsequently purchased the property. A Deed of Absolute Sale was purportedly executed by Dizon on February 24, 2000, and Matti paid the full purchase price. However, in August 2000, Matti discovered that the title and tax documents in his possession were falsified. The RD later issued a certification confirming the title was fake. Despite demands, Dizon failed to deliver the authentic title, prompting Matti to seek court intervention to compel delivery or issuance of a new title in his name.
Dizon denied the sale, asserting she had no cause of action against her. She claimed she did not execute the Deed of Absolute Sale, did not know Matti or the alleged agents, and was not in the Philippines during February 2000. To substantiate her defense, she presented a Certification from the Bureau of Immigration and the testimony of an immigration agent confirming her absence from the country throughout that month. The Regional Trial Court (RTC) dismissed Matti’s complaint, finding Dizon’s alibi credible and concluding the deed was invalid due to forgery and lack of consent.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s dismissal of the complaint and in ruling that the Deed of Absolute Sale was valid and binding.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the RTC’s decision. The Court held that the CA gravely erred in disregarding the RTC’s factual findings, which are generally binding on appeal. The core issue was the authenticity of the Deed of Absolute Sale and Dizon’s consent. The RTC’s conclusion that the deed was forged was firmly anchored on clear and convincing evidence: the official Bureau of Immigration Certification and unrebutted testimony proving Dizon was abroad for the entire month of February 2000, including the specific date of the alleged signing. This physical impossibility for Dizon to have personally executed the document was a decisive fact.
The legal logic centers on the essential requisites of a contract, particularly consent. A contract of sale requires the meeting of minds between the seller and buyer. The Supreme Court found that Dizon’s consent was completely absent, rendering the contract void. The CA’s reliance on the notarized deed’s presumed regularity was misplaced given the conclusive evidence of forgery. A notarized document’s presumption of authenticity is disputable and yields to contrary evidence. Here, the proof of Dizon’s absence was concrete and uncontroverted, leading to the inescapable conclusion that the deed was a sham. Consequently, Matti’s action for specific performance, which presupposes a valid contract, had no leg to stand on. The RTC correctly dismissed the complaint for lack of merit.