Sps. Manlan vs. Sps. Beltran

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DOCTRINE:  The Supreme Court is not a trier of facts and only questions of law must be raised

in a petition filed under Rule 45 of the Rules of Court. The SC accords finality on the factual
findings of the trial courts, especially when such findings are affirmed by the appellate court.

THIRD DIVISION

MR. AND MRS. ERNESTO MANLAN v. MR. AND MRS. RICARDO BELTRAN
G.R. No. 222530, October 16, 2019

INTING, J.

FACTS:

Sps. Manlan (petitioners) bought a parcel of land from Manuel Orbeta. After receiving
the advance payment, the latter was allowed to occupy such land. Subsequently, the Orbetas,
except Manuel who was already deceased, thus represented by his wife Emiliana Orbeta,
executed a Deed of Absolute Sale conveying the subject property to Sps. Beltran (respondents).
Thereafter, the said property was registered under the name of the respondents. The latter
demanded from petitioners to vacate the property but to no avail, hence, the respondents filed an
action of quieting of title against the petitioners. The respondents claimed to be the absolute
owners of the property. In their answer, petitioners alleged that they bought the said property and
as counterclaim, they contended that the Deed of Absolute Sale between the respondents and the
Orbetas, was fictitious, having been procured by eans of falsification and insidious scheme and
machination because at the time that it was notarized, Serbio Orbeta was already dead. The RTC
ruled in favor of the respondents. The trial court found that the notarization of the said Deed was
defective, nevertheless, ruled that the defect did not affect the legality of the conveyance from
the Orbetas to respondents. Moreover, it ruled that petitioners could not collaterally attack the
validity of respondent’s title. Thus, it upheld the transfer of rights from the Orbetas to
respondents. On appeal, the CA affirm the decision of the RTC. The CA found that the
respondnets were able to prove the authenticity and due execution of the questioned deed of sale.
The petitioners appealed the decision of the CA before the SC, through Ruled 45, arguing that
the CA erred in not considering that the respondents were in bad faith in purchasing the subject
property and the Deed of Absolute Sale is fraudulent as it was not validly notarized and the
defective notarization in the deed of sale affected the validity of the new TCT.
ISSUE:

Are the questions raised by the petitioners for the validity of the Deed of Absolute Sale
proper before the Supreme Court?

HELD:

NO.

The Supreme Court is not a trier of facts and only questions of law must be raised in a
petition filed under Rule 45 of the Rules of Court. The SC accords finality on the factual findings
of the trial courts, especially when such findings are affirmed by the appellate court. Although
said rule admits certain exceptions, none of which was proved here in this case. Thus, the Court
is not duty-bound to analyze and weigh all over again the evidence already considered in the
proceedings before the trial court. Petitioners proffer factual issues such as whether respondents
were in bad faith when they bought the property from the Orbetas and whether respondents
fraudulently executed the Deed of Absolute Sale. These factual matters are not within the
province of this Court to look into, save only in exceptional circumstances which are not present
here. As such, this Court gives credence to the factual evaluation made by the trial court which
was affirmed by the CA.

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