G.R. No. L-59514 February 25, 1988
PACIANO REMALANTE, petitioner, vs. CORNELIA TIBE and THE COURT OF APPEALS, respondents.

FACTS

The dispute involves the ownership of six parcels of land. Private respondent Cornelia Tibe filed a complaint seeking the annulment of documents that transferred these properties to petitioner Paciano Remalante. Tibe alleged that Remalante, through fraud and deceit, induced her to sign three affidavits of transfer, which she believed were bail bonds for his concubinage case, covering three parcels under her Tax Declaration Nos. 20280, 20273, and 20274. She further claimed that Remalante forged her signature on a deed of absolute sale for her three other parcels under Tax Declaration Nos. 13959, 17388, and 16999. Remalante denied these allegations, asserting absolute ownership. He claimed the first three parcels were purchased from Silvino Alminario and were only temporarily placed under Tibe’s name for a loan collateral that never materialized, leading to her signing the affidavits of transfer before the mayor. He presented the deed of sale as proof of the voluntary sale of the other three parcels.
The trial court rendered a split decision, annulling the deed of sale for the latter three parcels and awarding them to Tibe, but declaring Remalante the absolute owner of the first three parcels. Both parties appealed. The Court of Appeals reversed the trial court, annulling all disputed documents—the affidavits of transfer and the deed of sale—and awarded ownership of all six parcels to Tibe, ordering Remalante to pay attorney’s fees.

ISSUE

Whether the Court of Appeals erred in its factual findings and legal conclusions by awarding ownership of all six parcels of land to private respondent Cornelia Tibe.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court emphasized that factual findings of the Court of Appeals are generally conclusive and binding, and exceptions to this rule were not present. The Court upheld the appellate court’s assessment of the evidence, which found that Remalante procured Tibe’s signatures through misrepresentation. Critically, the Court applied Article 1332 of the Civil Code, which places the burden on the party enforcing a contract to show that its terms were fully explained to the other party if that party is unable to read or understand the language used. The evidence established that Tibe was illiterate and did not understand English, the language of the deed of sale (Exhibit 22). Remalante failed to discharge this burden of proof, rendering the contract voidable due to vitiated consent. The finding of fraud and misrepresentation in the execution of the affidavits of transfer was also sustained. Consequently, the Court of Appeals correctly annulled all instruments and restored ownership to Tibe, as its decision was based on a preponderance of evidence and in accord with law.