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TITAN CONSTRUCTION CORPORATION v. MANUEL A. DAVID

FACTS:

Martha S. David sold a property to Titan Construction Corporation, but Manuel A. David, Martha's husband, filed a complaint for annulment of contract and reconveyance against Titan. Manuel alleged that the sale executed by Martha was without his knowledge and consent, making it void. Titan claimed to be a buyer in good faith and for value, relying on a special power of attorney (SPA) signed by Manuel. However, Manuel claimed that the SPA was spurious and that his signature was forged. Despite being declared in default, Martha failed to answer the complaint. The Regional Trial Court (RTC) ruled in favor of Manuel, invalidating the sale and ordering Titan to reconvey the property. The Court of Appeals affirmed the RTC's decision but deleted the award of attorney's fees and costs. Titan filed a petition before the Supreme Court, raising various errors in the appellate court's decision.

ISSUES:

  1. Whether the property is part of the spouses' conjugal partnership.

  2. Whether the Deed of Sale is void in the absence of Manuel's consent.

  3. Whether the Special Power of Attorney purportedly signed by Manuel is spurious and void.

  4. Whether the factual findings of the trial court, adopted and confirmed by the Court of Appeals, are binding and conclusive.

  5. Whether the failure to specifically deny the genuineness and due execution of the Special Power of Attorney (SPA) in the reply constitutes an admission of the veracity of said document.

  6. Whether or not the Special Power of Attorney (SPA) was genuine or duly executed.

  7. Whether or not Titan Construction Corporation is a buyer in good faith.

  8. Whether the Court of Appeals committed a grave abuse of discretion in dismissing the petition for certiorari for lack of jurisdiction.

  9. Whether petitioners are entitled to the relief sought.

RULING:

  1. The property is part of the spouses' conjugal partnership. The Civil Code, as well as the Family Code, provides that all property acquired during the marriage is presumed to be conjugal unless proven otherwise. In this case, Titan failed to overturn the presumption that the property was part of the conjugal partnership.

  2. The Deed of Sale is void in the absence of Manuel's consent. Both the Civil Code and the Family Code require the consent of both spouses for any disposition or encumbrance of conjugal property. Since Manuel did not give his consent, the sale to Titan is void.

  3. The Special Power of Attorney purportedly signed by Manuel is spurious and void. The RTC found that the signature on the SPA was not genuine and the plaintiff's evidence, including the testimony of an expert witness, supported this finding. Moreover, the SPA violated the provisions of P.D. No. 1529 and was not presented for registration with the Quezon City Register of Deeds. Therefore, the SPA has no legal effect.

  4. The factual findings of the trial court, when adopted and confirmed by the Court of Appeals, are binding and conclusive. The Supreme Court accords great weight to the findings of the trial court, particularly in assessing the credibility of witnesses. There is no cogent reason to depart from the rulings of the lower courts.

  5. The failure to specifically deny the genuineness and due execution of the SPA in the reply does not constitute an admission of the veracity of said document. Even though the reply was not made under oath, the verified complaint, which alleged that the sale of the subject property was without the knowledge and consent of the plaintiff, placed the defendant on notice that they would be called upon during trial to prove the genuineness or due execution of the SPA. The interpretation of Rule 8, Section 7 of the Rules of Court should assist the parties in obtaining a just determination of the disputed issues.

  6. The court found that the SPA was not genuine or duly executed. The absence of one party's details and the testimony of the party that he did not sign the SPA, in addition to the expert testimony on the signature, support the finding that the SPA was forged.

  7. The court found circumstances that mitigate against Titan's claim of being a buyer in good faith. This includes the failure to include one party's civil status in the Deed of Sale, Titan's awareness of the possible need for the other party's consent, and Titan's actions without proper verification or caution in the transaction.

  8. The Court of Appeals did not commit a grave abuse of discretion in dismissing the petition for certiorari for lack of jurisdiction. The Court of Appeals correctly held that there was no showing that the Regional Trial Court (RTC) committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the assailed writ of execution. As such, the proper remedy was to file a motion for reconsideration before the RTC, not a petition for certiorari directly to the Court of Appeals.

  9. Petitioners are not entitled to the relief sought. The Court ruled that the petition for certiorari was devoid of merit. The RTC did not commit any grave abuse of discretion in issuing the writ of execution. The Court emphasized that jurisdiction over the res was already acquired by the RTC when it issued its final and executory decision, and that the writ of execution carried out by the sheriff was a ministerial duty in accordance with law.

PRINCIPLES:

  • The property acquired during the marriage is presumed to be part of the conjugal partnership, unless proven otherwise.

  • The consent of both spouses is required for any disposition or encumbrance of conjugal property.

  • A spurious and void document, such as a Special Power of Attorney, has no legal effect.

  • Factual findings of trial courts, when adopted and confirmed by the Court of Appeals, are binding and conclusive and will generally not be reviewed on appeal.

  • Only errors of law and not of fact are reviewable by the Supreme Court in a petition for review on certiorari.

  • The failure to specifically deny the genuineness and due execution of a document in the reply does not constitute an admission of its veracity, especially when the verified complaint places the opposing party on notice of the need to prove the genuineness or due execution of said document during trial.

  • A notarized document enjoys a prima facie presumption of authenticity and due execution, but this presumption can be overcome by clear and convincing evidence. Defects in the notarization of a document may mitigate against a finding of genuineness or due execution.

  • A forged SPA cannot be considered genuine or duly executed.

  • A buyer cannot claim to be in good faith if there are circumstances that indicate otherwise, such as awareness of missing consent or failure to verify important details.

  • Due process requires that a party be duly apprised of a claim against them before judgment may be rendered.

  • The proper remedy against an alleged error in a final judgment or order of the RTC is a motion for reconsideration filed in the RTC and not a petition for certiorari filed directly in the Court of Appeals or the Supreme Court.

  • A writ of execution issued by the RTC is a ministerial duty of the sheriff, as long as the RTC has already acquired jurisdiction over the res through its final and executory decision.