G.R. No. 250846 . January 05, 2022
SPS. RONICO LOPEZ AND MARCELINA LOPEZ, AND SPS. GLORIA LOPEZ ADORZA AND NICOMEDES ADORZA, PETITIONERS, VS. SPS. ADOLFO AND SUSANA POTOY, ET AL., RESPONDENTS.

FACTS

Petitioners filed a Complaint for Quieting of Title and Damages over a parcel of land registered under their names (TCT No. 28487, Lot No. 9194-B). The property originally formed part of Lot No. 9194 registered in the name of petitioners’ parents, Severino and Esperanza Lopez. Petitioners denied executing any deed of conveyance covering the subject property. Respondents countered that Severino and Esperanza, along with their children (including petitioners Ronico and Gloria), sold a two-hectare portion of Lot No. 9194 to Agustin Potoy in 1969, as evidenced by a notarized Deed of Absolute Sale. An Affidavit of Adverse Claim by Agustin was inscribed on the title. The Regional Trial Court (RTC) ruled in favor of petitioners, quieting their title and ordering respondents to respect their ownership. The RTC found respondents failed to prove their relationship to Agustin, to identify the specific portion sold, and cast doubt on the sale’s validity based on the Notary Public’s testimony. The Court of Appeals (CA) reversed the RTC, dismissing the complaint. The CA upheld the validity of the notarized Deed of Absolute Sale, accorded it the presumption of regularity, and found petitioners’ bare denials insufficient to overcome this presumption. Petitioners elevated the case to the Supreme Court.

ISSUE

Whether the Court of Appeals committed reversible error in dismissing the Complaint for Quieting of Title based on the presumption of regularity accorded to the notarized Deed of Absolute Sale.

RULING

The Supreme Court denied the petition and affirmed the CA Decision and Resolution. The notarized Deed of Absolute Sale is a public document that enjoys the presumption of regularity. To overcome this presumption, clear and convincing evidence is required. Petitioners failed to present such evidence, relying only on bare denials. The testimony of the Notary Public, Demosthenes Tugonon, who personally knew the parties and attested to their appearance and signing before him, carries greater credence. Petitioners did not allege forgery, and Gloria’s claim of minority at the time of sale was unsupported by competent evidence. Furthermore, respondents’ undisputed possession of the property since 1969 corroborated the sale’s existence. Consequently, petitioners failed to prove the second requisite for quieting title—that the deed casting a cloud on their title is invalid or inoperative. Thus, the Complaint was properly dismissed.