G.R. No. 225808 . September 11, 2017
SPOUSES EDGARDO M. AGUINALDO AND NELIA T. TORRES-AGUINALDO, PETITIONERS, VS. ARTEMIO T. TORRES, JR., RESPONDENT.

FACTS

Petitioners, the registered owners of three lots in Cavite, filed a complaint for annulment of sale, cancellation of title, and damages against respondent. They alleged that they discovered in December 2000 that the titles had been transferred to respondent based on a forged Deed of Absolute Sale dated July 21, 1979, which they did not execute. They sought to nullify this deed and the resulting Transfer Certificates of Title issued in respondent’s name.
Respondent denied involvement with the 1979 deed but asserted that a valid sale occurred through a Deed of Absolute Sale dated March 10, 1991. He claimed petitioners themselves caused the registration of the 1979 deed to effect the transfer and argued the action had prescribed. The Regional Trial Court dismissed the complaint, finding petitioners failed to prove their case by preponderance of evidence and noting Nelia Aguinaldo’s admission of the sale in a 1998 letter.

ISSUE

Whether the Court of Appeals committed reversible error in ruling that a valid conveyance of the subject properties to respondent existed and in ordering petitioners to execute a registrable deed of conveyance in his favor.

RULING

The Supreme Court modified the CA decision but ultimately affirmed the existence of a valid sale. The Court agreed with the CA’s finding that the 1979 deed was spurious and conveyed no title; therefore, the titles issued pursuant to it should be nullified, as prayed for in the complaint. However, the Court upheld the CA’s conclusion that a valid conveyance was established through the 1991 deed of sale.
The legal logic rests on the preponderance of evidence supporting the 1991 deed’s authenticity. The NBI confirmed the genuineness of petitioners’ signatures on this deed. Petitioners failed to rebut this evidence. Furthermore, Nelia’s 1998 letter to respondent explicitly acknowledged the sale and discussed payment terms, constituting a judicial admission. Respondent’s consistent payment of real property taxes from 1993 to 2003 also strongly indicates possession in the concept of an owner. While the 1991 deed was defectively notarized—as the parties signed in different locations—this defect does not invalidate the perfected contract of sale but merely renders the document inadmissible as a public document and unregistrable.
Consequently, under Articles 1357 and 1358 of the Civil Code, respondent, as a party to a perfected contract over immovable property, has the right to compel petitioners to execute a registrable deed in the proper form. The CA’s order directing petitioners to execute such a deed within thirty days is a proper enforcement of this right, consistent with the court’s authority under the Rules of Court to direct specific acts to fulfill a judgment.