Socorro P. Cabilao v. Ma. Lorna Q. Tampan

Summary

This case involves a dispute over ownership of residential property covered by TCT No. T-59 in Surigao City. Socorro Cabilao sold the property to Lorna Tampan-Naldoza in 1988 through a notarized deed of sale for P10,000.00, with Lorna's mother Antonieta acting as representative. Years later, Socorro entered into pacto de retro sales using the same title as collateral, then filed suit claiming the original sale was fraudulent and void. The RTC initially ruled for Socorro, finding the sale invalid due to gross inadequacy of price, lack of proper authorization, and suspicious circumstances. However, the Court of Appeals and Supreme Court both ruled for Lorna, holding that the notarized deed enjoyed presumption of regularity, Socorro failed to prove fraud, and the sale validly transferred ownership despite non-registration. The Supreme Court emphasized that documentary evidence prevails over testimonial evidence and that gross inadequacy of price alone doesn't invalidate contracts absent fraud.