View full case

SPS. EDGARDO M. AGUINALDO v. ARTEMIO T. TORRES

FACTS:

The Spouses Edgardo Aguinaldo and Nelia Torres-Aguinaldo (petitioners) filed a complaint for annulment of sale, cancellation of title, and damages against Artemio Torres, Jr. (respondent) before the Regional Trial Court (RTC) of Trece Martires City. The petitioners claimed to be the registered owners of three lots in Cavite, but discovered that the titles were transferred to the respondent through a Deed of Absolute Sale dated July 21, 1979 (1979 deed of sale). The respondent denied involvement in the 1979 deed of sale and asserted that the properties were validly sold to him through a Deed of Absolute Sale dated March 10, 1991 (1991 deed of sale). He alleged that the petitioners caused the registration of the 1979 deed of sale, and therefore, their action has prescribed. The RTC dismissed the complaint, finding that the petitioners failed to establish their claim by preponderance of evidence. On appeal, the Court of Appeals (CA) upheld the RTC's findings and concluded that while the 1979 deed of sale was spurious, there was a valid sale to the respondent based on the authenticity and due execution of the 1991 deed of sale. However, the CA noted that the 1991 deed of sale was improperly notarized, and thus, directed the petitioners to execute a registrable deed of conveyance in favor of the respondent. Dissatisfied, the petitioners filed a motion for reconsideration, which the CA denied. This prompted the petitioners to file a petition for review on certiorari before the Supreme Court.

ISSUES:

  1. Whether or not there was a valid conveyance of the subject properties to respondent.

  2. Whether or not the CA erred in directing petitioners to execute a registrable deed of conveyance in favor of respondent.

RULING:

  1. The Court affirmed the CA's ruling that there was a valid conveyance of the subject properties to respondent. The CA found that the 1979 deed of sale, which purportedly transferred title over the subject properties to respondent, was spurious. However, the CA also found that there was a valid sale based on the 1991 deed of sale, which contained genuine signatures of petitioners as established by NBI reports. The CA also considered Nelia's admission of the sale in her letter to respondent and respondent's payment of real property taxes on the subject properties as evidence of ownership.

  2. The Court also affirmed the CA's directive for petitioners to execute a registrable deed of conveyance in favor of respondent. The CA found that the 1991 deed of sale was improperly notarized and could not be properly registered. In order to rectify this, the CA ordered petitioners to execute a new deed of conveyance in accordance with Articles 1357 and 1358 (1) of the Civil Code.

PRINCIPLES:

  • A valid sale can still be upheld even if a previous deed of sale is found to be spurious, as long as there is sufficient evidence to establish the authenticity and due execution of another valid deed of sale.

  • A party claiming ownership of a property should provide evidence to support their claim, such as authentic documents and admission of the sale.

  • Real property taxes paid by a person can be considered as evidence of ownership and possession in the concept of an owner.

  • Improper notarization of a deed of sale may render it unregistrable, but the court may order the parties to execute a new deed of conveyance in order to rectify the error.