G.R. No. 228350 . October 10, 2022.
REGIDOR R. TOLEDO, RONALDO TOLEDO, JOEFFREY TOLEDO, AND GLADDYS TOLEDO, PETITIONERS, VS. JERRY R. TOLEDO AND JELLY R. TOLEDO, RESPONDENTS.

FACTS

The case involves a dispute over an agricultural land originally owned by Florencia Toledo. Before her death, Florencia executed two Deeds of Absolute Sale in 2002, selling portions of the land to her grandchildren, respondents Jerry and Jelly Toledo. After Florencia’s passing, her other grandchildren, the petitioners, filed a complaint for annulment of the deeds. They alleged fraud and undue influence, claiming Florencia was weak and bedridden, and was manipulated into signing without understanding the documents. They presented a Sinumpaang Salaysay dated December 7, 2002, where Florencia purportedly stated she signed a folded paper without knowing its contents and that she did not intend to transfer her land.
The Regional Trial Court dismissed the complaint, finding no clear evidence of fraud or undue influence. The Court of Appeals affirmed this decision. It acknowledged irregularities in the notarization of the deeds, as Florencia did not personally appear before the notary public, which reduced the documents to private instruments. However, the CA ruled that respondents successfully proved the deeds’ due execution and authenticity through testimonial and documentary evidence. The CA also denied petitioners’ motion to present newly discovered evidence—certifications from the National Archives stating no notarial records for the deeds were on file—finding the evidence could have been discovered earlier with due diligence.

ISSUE

The sole issue for resolution is whether the Deeds of Absolute Sale executed by Florencia Toledo in favor of the respondents are valid.

RULING

The Supreme Court denied the petition and upheld the validity of the deeds. The Court emphasized that the issue of a deed’s genuineness is factual, and in a Rule 45 petition, it generally does not re-examine evidence unless there are exceptional circumstances, which were absent here. The legal logic centered on the burden of proof and the presumption of regularity in private transactions. Petitioners failed to present clear and convincing evidence to overcome the presumption that the deeds were voluntarily executed. The Sinumpaang Salaysay was deemed insufficient to invalidate the sales; it was a general, unsubstantiated claim that did not specifically repudiate the subject deeds. In contrast, respondents presented witnesses, including a petitioner who was present during one signing, who testified to Florencia’s conscious and voluntary execution.
Regarding notarial defects, the Court agreed with the CA that the lack of personal appearance only stripped the deeds of public document status, rendering them private documents. Their authenticity was nonetheless established. The alleged newly discovered evidence from the National Archives was correctly excluded, as it did not meet the requisites for a new trial and, even if considered, did not prove the deeds were fictitious—the absence of records was a separate administrative concern for the notary. The Court found no proof of simulation; the deeds contained clear consideration and transfer of ownership. Thus, the deeds were upheld as valid conveyances of property.