G.R. No. L-44344. July 16, 1990.
FELIPA GREGORIO, ISABEL SALVADOR, TACIANA SALVADOR, ARTEMIO SALVADOR, MAURA SALVADOR, BONIFACIO SALVADOR, SUSANA SALVADOR, PAULINA ALEJANDRO, DANIEL ALEJANDRO, CRISTOBAL ALEJANDRO, EPIFANIO ALEJANDRO, RODOLFO ALEJANDRO, ROSITA ALEJANDRO, and PAULINO DE LA CRUZ, petitioners, vs. COURT OF APPEALS, and MARIA GREGORIO, together with GLICERIA, SERGIO and DOMINGO, all surnamed MIRANDA, respondents.

FACTS

The case involves a parcel of land originally owned by the spouses Candido Gregorio and Simeona Trinidad. Upon Candido’s death in 1908, the property was inherited by his widow Simeona and their five children: Maria, Valentina, Ignacia, Francisca, and Felipa. On October 9, 1948, several heirs and representatives executed a notarized document titled “Kasunduan ng Pagpapatibay ng Karapatan sa Lupa” (Exhibit “O”). This instrument, for a consideration of P400.00, conveyed and transferred all their rights and ownership interests in the subject land to their sister, Maria Gregorio. The signatories included Paulino de la Cruz (son of the deceased Valentina), Ignacia Gregorio, Felipa Gregorio, and Dominador Alejandro (husband of the deceased Francisca), with the consent of the widow Simeona Trinidad.
Based on Exhibit “O,” Maria Gregorio and her children filed an application for land registration in 1964. The application was opposed by Felipa Gregorio, the heirs of Ignacia and Francisca, and Paulino de la Cruz, who collectively claimed ownership over 4/5 of the property. They argued that Exhibit “O” was void due to fraud or mistake, that Maria did not possess the land exclusively, and that a subsequent transfer by Maria to her husband was null and void. The Land Registration Court granted the application, a decision affirmed by the Court of Appeals.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the Land Registration Court’s decision which upheld the validity of Exhibit “O” and confirmed Maria Gregorio’s title, thereby ordering registration in her and her children’s favor.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. The petition was essentially a request for the Supreme Court to re-evaluate the factual findings of the lower courts, which is impermissible in a petition for review on certiorari. The Court’s jurisdiction in such appeals is limited to reviewing questions of law, not re-examining the evidence or factual conclusions. The petitioners’ arguments—challenging the genuineness of Exhibit “O” due to fraud, disputing Maria’s exclusive possession, and questioning the transfer to her husband—were all factual in nature.
The Supreme Court found no compelling reason to deviate from the factual findings of the Court of Appeals and the Land Registration Court. These lower courts had conclusively found that the evidence preponderantly established the validity of Exhibit “O” as a genuine conveyance. The presumption of regularity of notarized documents and the fairness of transactions remained unrebutted by credible evidence. The Court of Appeals correctly held that Maria Gregorio became the sole owner, having inherited a portion and validly acquired the remaining shares from her co-heirs. Furthermore, her exclusive possession and enjoyment of the property’s fruits after 1948, without protest, supported her claim of ownership. The alleged transfer to her husband was deemed incon