G.R. Nos. L-50374-76 September 24, 1986
ESTATE OF RODOLFO JALANDONI, represented by his Judicial Administrator, BERNARDO JALANDONI, petitioner, vs. THE HONORABLE COURT OF APPEALS, FRANCISCO D. PALANCA and LOURDES MONTAÑER, respondents.

FACTS

The case involves consolidated actions concerning the validity of transactions executed by Rodolfo Jalandoni over his property in Manila. The transactions included two lease contracts (from 1959 and 1963) with a group later incorporated as Sampaguita Crafts Center, Inc., and a subsequent absolute sale of the same property to Francisco D. Palanca in December 1963, facilitated by broker Lourdes Montañer. Following the sale, Palanca attempted to increase rents and terminate the lease, prompting the lessees to sue for recognition of their leasehold rights. Montañer separately sued to collect her broker’s commission. Rodolfo Jalandoni’s judicial guardian, Bernardo Jalandoni, filed a third action seeking to annul the sale to Palanca, alleging that Rodolfo was of unsound mind and legally incapable of consenting to the contracts at the time of their execution. This defense of insanity was also interposed in the other two suits. Rodolfo Jalandoni died during the pendency of the litigation in the Court of First Instance.
The trial court extensively received evidence on Jalandoni’s mental state. The guardian presented testimonial and expert evidence, including a neuro-surgeon who performed a lobotomy on Jalandoni and a psychiatrist who diagnosed him as a chronic schizophrenic, casting doubt on his competency in 1963. In contrast, respondents Montañer and Palanca presented lay witnesses who testified to Jalandoni’s seemingly normal behavior during the transactions. The trial court ultimately found the contracts valid, a decision affirmed by the Court of Appeals, which gave greater weight to the testimony of the respondents’ witnesses regarding Jalandoni’s apparent lucidity.

ISSUE

The principal issue is whether the Court of Appeals erred in affirming the trial court’s factual finding that Rodolfo Jalandoni was of sound mind at the time he executed the lease contracts and the deed of absolute sale, thereby upholding the validity of these transactions.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The Court reiterated the fundamental rule that factual findings of the Court of Appeals are final, conclusive, and not reviewable by the Supreme Court in a petition for review on certiorari, absent any of the recognized exceptions. The core controversy—Jalandoni’s mental capacity—is purely a question of fact, resolvable only through the evaluation of the evidence presented. Both lower courts meticulously assessed the conflicting testimonies and found the evidence of the respondents, consisting of disinterested witnesses who interacted with Jalandoni during the relevant period, to be more credible and convincing regarding his apparent sanity. The Supreme Court, after its own review of the record, found no reason to deviate from this conclusion, as the appellate court’s findings were supported by a preponderance of evidence. The legal effects of proven insanity were not in dispute; the case turned entirely on the factual determination of his mental state, which the Court of Appeals correctly resolved.