In the case of Llana v. Court of Appeals, the Supreme Court affirmed the principle that a duly notarized deed of sale carries a strong presumption of regularity and validity. This presumption can only be overturned by clear, convincing, and more than merely preponderant evidence. The ruling highlights the importance of upholding contractual agreements and provides a framework for evaluating claims of simulated or misrepresented transactions, emphasizing that self-serving testimonies alone are insufficient to invalidate a legally executed document.

Challenging a Sale: Can Testimony Alone Overturn a Notarized Deed?

The case revolves around a dispute over several parcels of land in Ilocos Norte. Private respondents, Nicanor Pagdilao, et al., filed an action to quiet title against petitioners Aurelia Llana, et al., claiming ownership based on deeds of sale executed in their favor by the petitioners. The petitioners, however, argued that these deeds were simulated and did not reflect the true intention of the parties. They claimed that the transfers were made to prevent the properties from being attached due to a homicide case against Aurelia Llana’s husband, Bonifacio Llana. The central legal question is whether the petitioners presented sufficient evidence to overcome the presumption of validity of the notarized deeds of sale.

The petitioners sought to invalidate the deeds of sale through parol evidence, specifically the testimony of Aurelia Llana. They argued that the documents did not reflect the parties’ true intentions and were executed solely for the purpose of protecting the properties from potential attachment. However, the Court of Appeals, affirming the trial court’s decision, found that the petitioners failed to adduce clear and convincing proof to support their claims. The appellate court emphasized that duly notarized documents are presumed valid, and this presumption can only be overturned by substantial evidence.

The Supreme Court reiterated the principle that it is not a trier of facts and generally does not review factual findings of the lower courts, especially when the Court of Appeals affirms the trial court’s findings. The Court emphasized that only errors of law are reviewable in a petition for review under Rule 45 of the Revised Rules of Court. Both the Court of First Instance (CFI) and the Court of Appeals (CA) found that the conveyances of the lands were documented by valid deeds of sale, duly notarized and registered. These findings were central to the Supreme Court’s decision.

The Court addressed the admissibility of parol evidence, referencing Section 9, Rule 130 of the Revised Rules of Court, which states that when an agreement is reduced to writing, the written agreement is deemed to contain all the terms agreed upon. However, an exception exists when the validity of the agreement is at issue, allowing parol evidence to modify, explain, or add to the terms. Since the validity of the deeds of sale was contested, the CFI correctly allowed the petitioners to present parol evidence.

However, the evidence presented by the petitioners, primarily the testimony of Aurelia Llana, was deemed insufficient to overcome the presumption of regularity afforded to notarized documents. The Court highlighted that a document acknowledged before a notary public enjoys the presumption of regularity and is prima facie evidence of the facts stated therein. The Court quoted the ruling in Caoili vs. Court of Appeals, 314 SCRA 345, 361 (1999), stating that:

“To overcome this presumption, there must be presented evidence which is clear, convincing and more than merely preponderant. Absent such evidence, the presumption must be upheld.”

The Supreme Court thus affirmed that the self-serving testimony of a party with a vested interest in the outcome of the case cannot outweigh the evidentiary weight of a notarized document.

Furthermore, the Court noted the lack of corroborating evidence to support Aurelia’s claim that the debt of P5,000.00 plus interest had been paid. The deed of sale dated July 26, 1966, did not indicate that the two lots in Barangay Nagbacsayan were conveyed to Nicanor in payment of the debt. The court requires solid proof to substantiate claims, especially when challenging documented transactions. Thus, the Court upheld the validity of the deeds of sale and affirmed the private respondents’ ownership of the properties in question.

FAQs

What was the key issue in this case?	The key issue was whether the petitioners presented sufficient evidence to overcome the presumption of validity of the notarized deeds of sale conveying the properties to the private respondents.
What is parol evidence?	Parol evidence is oral or extrinsic evidence that is not contained in the written agreement itself. It can be used to explain, modify, or add to the terms of a written contract under certain circumstances, such as when the validity of the agreement is in question.
What is the legal effect of a notarized document?	A document notarized by a notary public is presumed to be regular and valid. It serves as prima facie evidence of the facts stated therein, and this presumption can only be overcome by clear, convincing, and more than merely preponderant evidence.
Why was Aurelia Llana’s testimony deemed insufficient?	Aurelia Llana’s testimony was deemed insufficient because it was self-serving and not supported by other credible evidence. As a party with an interest in the outcome of the case, her testimony alone could not overcome the presumption of validity of the notarized deeds of sale.
What is the significance of this case for property transactions?	This case underscores the importance of ensuring that property transactions are properly documented and notarized. It highlights that the courts will generally uphold the validity of notarized documents unless there is clear and convincing evidence to the contrary.
Can a deed of sale be invalidated based on oral testimony alone?	Generally, no. While oral testimony can be presented to challenge the validity of a deed of sale, it must be clear, convincing, and more than merely preponderant to overcome the presumption of regularity afforded to notarized documents.
What kind of evidence is needed to challenge a notarized deed of sale successfully?	To successfully challenge a notarized deed of sale, one must present evidence that is clear, convincing, and more than merely preponderant. This may include documentary evidence, credible witness testimonies, and other evidence that proves the deed was simulated, fraudulent, or did not reflect the true intentions of the parties.
What was the Court’s ruling on the alleged debt payment?	The Court ruled that there was insufficient evidence to prove that Bonifacio Llana had paid his debt to Nicanor Pagdilao. The deed of sale presented as evidence of payment did not indicate that the lots were conveyed in satisfaction of the debt, and Aurelia’s testimony alone was insufficient to prove payment.

The Supreme Court’s decision in Llana v. Court of Appeals reinforces the legal stability of documented transactions and serves as a reminder that parties must present strong evidence to challenge the validity of notarized agreements. This ruling protects the integrity of contracts and provides a framework for evaluating claims of misrepresentation or simulation in property transactions, safeguarding the rights of those who rely on duly executed legal documents.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Aurelia S. Llana, et al. v. Court of Appeals, G.R. No. 104802, July 11, 2001