San Juan vs. Offril

A notarized deed of sale does not enjoy an absolute presumption of validity; its regularity may be overthrown by clear and convincing evidence of forgery, inconsistent conduct, and highly questionable circumstances attending its execution and registration. The lone testimony of a credible witness, if found truthful by the trial court, is sufficient to rebut the presumption.

Celeste M. Offril was the registered owner of a 264-square-meter lot in Makati City improved with a five-door apartment. Ma. Corazon San Juan leased one door. In 1990, Offril needed a loan and delivered her owner’s duplicate certificate of title to San Juan so the latter could apply for a bank loan and lend the proceeds to Offril. Without Offril’s knowledge, two deeds of sale—dated April 2, 1979 and June 14, 1979—were subsequently presented, resulting in the subdivision of the lot into six sublots and the issuance of separate certificates of title in San Juan’s name. Offril alleged that the deeds were spurious, her signatures forged, and no consideration was ever received. San Juan countered that the sales were genuine and fully paid.

• Ownership and Lease: Offril owned a 264-square-meter lot in Makati with a five-door apartment. San Juan was a lessee of one door.
• Delivery of Certificate of Title: Sometime in 1990, Offril needed a loan. San Juan convinced her to hand over the owner’s duplicate of TCT No. (114181) S-24948 so San Juan could present it to a bank for a loan, the proceeds of which she would lend to Offril.
• Purported Sales and Subdivision: Without Offril’s knowledge, two “Deed[s] of Sale of Unsegregated Portion” dated April 2, 1979 and June 14, 1979 surfaced. By virtue of these deeds, San Juan caused the subdivision of the lot into six sublots—Lots 20-A to 20-F—and secured separate TCTs in her name.
• Offril’s Allegation of Fraud: Offril claimed she never sold the property, the signatures in the deeds were forged, and she received no consideration. She learned of the cancellation of her title only after her granddaughter was informed by a personnel at the Assessor’s Office of Makati City.
• San Juan’s Defense: San Juan maintained that she acquired the property through valid sales, paying in cash and by checks encashed by Offril’s granddaughter, Consuelo Gorostiza, acting as attorney-in-fact.
• The Deed of Partition: During the proceedings, Offril presented a “Deed of Partition” executed on May 2, 1990 between herself and San Juan. The document adjudicated only Lots 20-A and 20-B to San Juan and recognized the remaining lots as Offril’s. San Juan did not deny executing the deed or object to its admission.
• Trial Court’s Factual Findings: The RTC found Offril’s testimony credible. It noted that in 1979, when the deeds were supposedly executed, San Juan was not yet a lessee; had she acquired the entire property then, there would have been no reason for her to sign a lease contract in 1988 and subdivide the property only in 1990. The deeds, though dated 1979, were presented for registration only in 1990. The Deed of Partition contradicted San Juan’s claim of full ownership, and the parties’ participation in it established that only Lots 20-A and 20-B were intended to be sold. The two 1979 deeds were consequently held to have no probative value and were declared spurious.

• Presumption of Regularity: Petitioner argued that Offril failed to overcome the presumption of validity attaching to the notarized deeds of sale and the TCTs in her name. She insisted the trial court never found her signatures to be forgeries.
• Credibility of Offril: Petitioner maintained that Offril’s testimony was unreliable because Offril suffered from Alzheimer’s disease or loss of memory, as shown by her failure to recall personal details during cross-examination.
• Best Evidence of Ownership: Petitioner contended that the TCTs in her name, which enjoy a strong presumption of regularity, should prevail over Offril’s uncorroborated testimony.
• Immateriality of Deed of Partition: Petitioner claimed the partition agreement was irrelevant to the issue of forgery and was merely a safety precaution because payment for the remaining lots was still to be made in future installments. She further argued that estoppel by the partition applied only against Offril, not against her.
• Antedating of Deeds: Petitioner pointed out that the second and third deeds were antedated—a fact never disputed—and that antedating was immaterial because Offril’s cause of action rested on forgery, not on the date of execution.

• Forgery and Lack of Consent: Respondent (through Offril’s substituted heirs) maintained that Offril never sold the property; the deeds were spurious, the signatures forged, and no consideration was ever paid. Offril’s testimony was clear, unequivocal, and rang with truth.
• Rebutted Presumption: Respondent countered that the suspicious circumstances—the 1979 dating of the deeds despite registration only in 1990, the continued tenancy of San Juan, and the contradictory Deed of Partition—sufficed to overcome the notarized documents’ presumption of regularity.

• Validity of Conveyance and Presumption of Regularity: Whether the notarized deeds of sale validly transferred the entire property to San Juan, or whether the evidence of forgery and attendant circumstances overcame their presumption of regularity.
• Credibility of Offril’s Testimony: Whether the trial court erred in giving full credence to Offril’s testimony despite her alleged memory lapses and purported Alzheimer’s disease.
• Estoppel by Deed of Partition: Whether San Juan was estopped by the Deed of Partition from claiming ownership of the whole property.

• Validity of Conveyance and Presumption of Regularity: The notarized deeds were properly annulled. A notarized document’s presumption of regularity is not absolute and may be rebutted by clear and convincing evidence. Here, the presumption was overthrown by highly questionable circumstances: the deeds were dated 1979 but registered only in 1990; San Juan was not yet a lessee in 1979 and later signed a lease with Offril in 1988; and the Deed of Partition, executed in 1990, limited San Juan’s acquisition to only two lots. Offril’s lone testimony that she never sold the entire property was found credible and sufficed to rebut the presumption.
• Credibility of Offril’s Testimony: The trial court’s assessment of Offril’s credibility was accorded great weight. The claim of Alzheimer’s disease was unsubstantiated by proof and had already been rejected by both lower courts. While Offril forgot certain personal details, her testimony on all matters material to the complaint—that she knew San Juan as a mere tenant, never sold the five-door apartment, and did not sign the questioned deeds—was clear, unequivocal, and consistent. The trial court, which had the opportunity to observe her demeanor, found her truthful.
• Estoppel by Deed of Partition: San Juan was estopped by the Deed of Partition. She did not deny its existence, her signature, or its admission into evidence. The deed demonstrated that Offril did not intend to dispose of, and San Juan did not intend to acquire, the entire property. The partition would have been unnecessary had San Juan truly owned the whole property as early as 1979. By her own participation, San Juan was bound to the extent of rights defined in that instrument.

• Rebuttable Presumption of Regularity of Notarized Documents — The presumption that a notarized document is regular and valid is not absolute. It may be overthrown by clear and convincing evidence of forgery, inconsistent conduct, or circumstances that render the document’s authenticity highly dubious. Once the prima facie validity is challenged and rebutted, the party relying on the document must adduce further proof of its due execution.
• Sufficiency of a Single Credible Witness — The testimony of a lone witness, if found credible by the trial court, is sufficient to prove a fact in issue and may even outweigh the presumption of regularity of a public instrument.
• Non-Interference with Trial Court’s Credibility Findings — Appellate courts will generally not disturb the trial court’s assessment of the credibility of witnesses, absent a showing that the trial court overlooked material facts or circumstances. The trial court is in a better position to gauge the truthfulness of testimony based on the witness’s demeanor and deportment on the stand.
• Estoppel by Deed — A party who executes and admits a deed that defines the extent of her rights over property is estopped from asserting a claim contrary to the recitals of that instrument.

• “While indeed, a notarized document enjoys this presumption, the fact that a deed is notarized is not a guarantee of the validity of its contents. The presumption is not absolute and may be rebutted by clear and convincing evidence to the contrary.”
• “The lone testimony of a witness, if credible, is sufficient.”
• “The Court has repeatedly held that it will not interfere with the trial court's determination of the credibility of witnesses, unless there appears on record some fact or circumstance of weight and influence which has been overlooked or the significance of which has been misinterpreted. The reason for this is that the trial court is in a better position to do so because it heard the witnesses testify before it and had every opportunity to observe their demeanor and deportment on the witness stand.”

• Nazareno v. Court of Appeals, G.R. No. 138842, October 18, 2000, 343 SCRA 637 — Cited for the rule that factual findings of the Court of Appeals, especially when coinciding with those of the trial court, are conclusive; also for the doctrines that a notarized document’s presumption is not absolute and that a lone credible witness is sufficient.
• Suntay v. Court of Appeals, 251 SCRA 452 (1995) — Referred to in Nazareno and applied for the principle that the presumption of regularity of notarized documents is not a guarantee of the validity of their contents.
• Mayor v. Belen, G.R. No. 151035, June 3, 2004, 430 SCRA 561 — Followed for the rule that the presumption of regularity cannot apply where the regularity of execution was successfully challenged in the proceedings below.
• People v. Conde, G.R. No. 133647, April 12, 2000, 330 SCRA 645 — Relied upon for the principle that appellate courts will not disturb the trial court’s credibility findings absent overlooked facts.

• N/A (No specific codal article or statutory provision was directly invoked or applied; the decision turned on general principles of evidence and civil law.)

• Conchita Carpio Morales (Acting Chairperson)
• Presbitero J. Velasco, Jr.
• Teresita Leonardo de Castro
• Arturo D. Brion

• None.