Dr. Lorna C. Formaran v. Dr. Glenda B. Ong

Summary

The Supreme Court resolved a property ownership dispute involving a contested Deed of Absolute Sale executed by Dr. Lorna Formaran in favor of Dr. Glenda Ong over land previously donated to Formaran. The Court found the sale to be absolutely simulated and void, citing seven badges of bad faith including lack of consideration, the buyer being the donor's daughter, delayed registration after 24 years, continuous possession by the seller, and the seller's ability to mortgage the property. The decision reinforced the Civil Code provisions on contract simulation and emphasized that notarization alone cannot validate a fictitious contract never intended to have binding legal effect. The case demonstrates the Court's careful examination of surrounding circumstances to determine the true nature of property transactions between related parties.