Constantino v. CA

G.R. No. 116018 (November 13, 1996)

Court denied Nelia A. Constantino's annulment, citing lack of consent and evidence of fraud.

Facts:

Josefa Torres died intestate, leaving behind a parcel of land in Balagtas, Bulacan, which was co-owned by her heirs, including respondents Aurora S. Roque, Priscilla S. Luna, and Josefina S. Austria. In 1984, the heirs entered into a contract to sell a 250-square meter portion of the land to petitioner Nelia A. Constantino. The heirs authorized Constantino to prepare the necessary Deed of Extrajudicial Settlement of Estate with Sale, which was left incomplete with several blank spaces, including the metes and bounds of the property.

After the heirs signed the document, it was agreed that Roque would be present for the land survey. However, the property was surveyed and subdivided without the heirs' participation, resulting in the issuance of Transfer Certificates of Title (TCT Nos. T-292265 and T-292266) that included areas not agreed upon, specifically a portion occupied by spouses Severino and Consuelo Lim.

On June 2, 1986, the heirs sent a demand letter to Constantino for the surrender of the deed and related documents, but she did not comply. Consequently, the heirs filed a case in the Regional Trial Court of Bulacan for annulment of the deed and cancellation of the titles, along with a claim for damages and attorney's fees.

In her defense, Constantino presented the Deed of Extrajudicial Settlement of Estate with Sale, asserting that the heirs had agreed to the division of the property and the sale of Lot 4-B. The trial court, however, found inconsistencies in Constantino's claims, particularly regarding the timing of the signing of the deed and the survey of the land.

Legal Issues:

  1. Whether the Deed of Extrajudicial Settlement of Estate with Sale was validly executed and reflected the true intent of the parties.
  2. Whether the trial court erred in denying Constantino's motion to admit formal evidence based on technical grounds.
  3. Whether the elements of fraud vitiating consent were present in the execution of the deed.

Arguments:

  • Petitioner (Constantino):

    • Argued that the trial court disregarded her documentary evidence on technical grounds and that the deed reflected the true intent of the parties.
    • Claimed that the heirs had signed the document after the survey was completed and that the notarization in Manila did not affect the validity of the deed.
    • Asserted that the demand letter from the heirs should not be taken as conclusive evidence of their claims.
  • Respondents (Heirs):

    • Contended that they did not consent to the sale of the property as the deed was signed before the land was surveyed, and they were not informed of the survey.
    • Argued that the deed was incomplete at the time of signing, as it contained blank spaces, and that they were misled into signing it.
    • Emphasized that the notarization in Manila raised doubts about the procedural regularity of the deed's execution.

Court's Decision and Legal Reasoning:

The trial court annulled the Deed of Extrajudicial Settlement of Estate with Sale and canceled the corresponding titles, finding that the deed did not reflect the true intent of the parties due to the lack of a meeting of the minds regarding the area to be sold. The court noted that the heirs signed the document before the survey was conducted, which was corroborated by the testimony of Constantino's own witness.

The Court of Appeals upheld the trial court's decision, emphasizing that the evidence supported the heirs' claims of fraud. The court found that Constantino had deceived the heirs by filling in the blank spaces in the deed after they had signed it, which constituted fraud that vitiated their consent.

The Supreme Court affirmed the lower courts' decisions, ruling that the trial court acted correctly in denying Constantino's motion to admit evidence due to her failure to comply with court orders. The Court also reiterated that the notarization of the deed did not validate it if the signatories did not actually consent to its terms.

Significant Legal Principles Established:

  1. Fraud Vitiating Consent: The presence of fraud in the execution of a contract can lead to its annulment if it induces a party to enter into the contract without true consent.
  2. Meeting of the Minds: A valid contract requires a meeting of the minds on the essential terms, including the subject matter and its extent.
  3. Procedural Compliance: Courts may deny motions to admit evidence if the party fails to comply with procedural requirements, emphasizing the importance of timely and proper adherence to court orders.