G.R. No. 96770. March 30, 1993.
HERMENEGILDO AGDEPPA (substituted by his heirs) vs. EMILIANO IBE (substituted by her husband FRUCTUOSO IBE and children LOLITA and CESAR IBE), BENJAMIN IBE and FERDINAND IBE.

FACTS

Rosario Igarta died single and without issue on October 19, 1986. Her nearest relatives were her sister Emiliana Ibe and her nephew Hermenegildo Agdeppa (son of her predeceased sister Carmen Agdeppa). Rosario’s properties were in the possession of the Ibe family. Hermenegildo Agdeppa, along with the sons of his deceased brother Jose, filed a complaint for partition of Rosario’s estate against Emiliana Ibe (later substituted by her husband and children), Benjamin Ibe, and Ferdinand Ibe. The defendants claimed that several properties had been conveyed by Rosario to them through deeds of quitclaim, transfer of ownership, and absolute sale executed in 1984 and 1985. The trial court nullified these documents, finding them defective because the residence certificate numbers appearing therein belonged to other persons per a certification from the municipal treasurer. The trial court also noted anomalies, such as multiple documents executed on the same day conveying the same property. The Court of Appeals reversed, upholding the validity of the documents. Petitioners elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the Court of Appeals erred in upholding the validity of the notarized deeds of conveyance executed by Rosario Igarta in favor of the respondents.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. The petition for certiorari is limited to reviewing errors of law. While factual findings of the Court of Appeals are generally conclusive, exceptions exist when there is a conflict with the trial court’s findings, necessitating review. Here, the trial court relied on a certification (Exhibit F) from the municipal treasurer to show that the residence certificate numbers in the deeds belonged to other persons. However, Exhibit F was merely secondary evidence based on lost pages of an abstract of residence certificates, making its evidentiary value suspect. The deeds, being notarized public documents, enjoy the presumption of validity. To overcome this presumption, clear, convincing, and more than merely preponderant evidence is required. Petitioners failed to present such evidence. The discrepancies in residence certificate numbers were explained by the witness Florante Rosal, who prepared the documents, as a possible mistake, and this testimony was unrebutted. The fact that multiple documents were executed on the same day or conveyed the same property did not invalidate them, as it merely showed Rosario’s preference for Benjamin Ibe, who cared for her. No clear and convincing evidence of forgery, lack of consideration, or invalidity was adduced. Thus, the presumption of regularity stands, and the deeds are upheld.