Cited Laws
TL;DR — Ruling
WHEREFORE, premises considered, judgment is rendered in favor of the [respondents] and against the [petitioners], upholding the validity of the Deed of Absolute Sale, dated December 30, 1989 and accordingly dismissing the complaint. The counterclaim is likewise ordered dismissed for lack of evidence to substantiate the same. [18] Petitioners filed a Notice of Appeal, which was given due course by the RTC in its Order [19] dated October 26, 2009.
WHEREFORE, premises considered, judgment is rendered in favor of the [respondents] and against the [petitioners], upholding the validity of the Deed of Absolute Sale, dated December 30, 1989 and accordingly dismissing the complaint. The counterclaim is likewise ordered dismissed for lack of evidence to substantiate the same. [18] Petitioners filed a Notice of Appeal, which was given due course by the RTC in its Order [19] dated October 26, 2009. Petitioners' appeal before the Court of Appeals was docketed as CA G.R. CV No. 94340. In its Decision dated September 7, 2012, the Court of Appeals affirmed the RTC Decision. The appellate court denied petitioners' Motion for Reconsideration in its Resolution dated February 11, 2013. Hence, petitioners filed the instant Petition, raising the sole issue of: WHETHER THE HONORABLE COURT OF APPEALS ERRED IN AFFIRMING THE TRIAL COURT'S DECISION UPHOLDING THE VALIDITY OF THE SUBJECT DEED OF SALE. [20] The core of petitioners' argument is that the Deed of Absolute Sale dated December 30, 1989 is void and inexistent absent the spouses Gatan's consent, considering that Bernardino's signature on said Deed was forged and the same Deed lacked petitioner Rogelia's marital consent. Petitioners maintain that Bernardino, who was unschooled, could not have affixed his signature on the Deed of Absolute Sale without the assistance of petitioner Rogelia, who signed for and in behalf of Bernardino whenever the latter's signature was needed. Moreover, petitioner Rogelia disavows giving her marital consent to the sale by affixing her signature on the Deed of Absolute Sale as Aurelia Ramos Gatan. Petitioners also asseverate that Bernardino was never married to one Aurelia Ramos Gatan. The Petition at bar is without merit. A cursory reading of the present Petition for Review on Certiorari under Rule 45 of the Rules of Court reveals that it is a reiteration of factual issues and arguments raised by petitioners in their appeal, which had already been fully passed upon by the Court of Appeals. Whether or not the signatures of Bernardino and petitioner Rogelia appearing on the Deed of Absolute Sale are forgeries is a question of fact which is beyond this Court's jurisdiction under the present Petition for Review on Certiorari . Questions of fact, which would require a re-evaluation of the evidence, are inappropriate under Rule 45 of the Rules of Court. The jurisdiction of the Court under Rule 45, Section 1 [21] is limited only to errors of law as the Court is not a trier of facts. While Rule 45, Section 1 is not absolute, none of the recognized exceptions, [22] which allow the Court to review factual issues, exists in the instant case. The following discussion in Miro v. Vda. de Erederos [23] is particularly instructive on this matter: Parameters of a judicial review under a Rule 45 petition a. Rule 45 petition is limited to questions of law Before proceeding to the merits of the case, this Court deems it necessary to emphasize that
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