Petitioner
Norma M. Diampoc
Respondent
Jessie Buenaventura
Citation
G.R. No. 200383
Court
Supreme Court
Division
First Division
Ponente
Del Castillo, J.
Decided
March 19, 2018

Summary

The Supreme Court affirmed lower courts' decisions upholding the validity of a deed of sale for real property despite petitioners' claims of fraud. Petitioner Norma Diampoc and her husband alleged they were deceived into signing a deed of sale for half their property, believing it was loan authorization. However, the Court found they failed to overcome the presumption of validity of the notarized document with clear and convincing evidence. Being educated individuals, they were held negligent for failing to read the document before signing. The Court emphasized that defective notarization does not invalidate the underlying contract and applied the preponderance of evidence standard. The decision reinforces the principle that parties cannot escape contractual obligations due to their own negligence and that courts will not relieve parties from unwise agreements entered into with proper formalities.

Statutes applied

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By Intellegal Editorial Board · March 19, 2018

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