- Petitioner
- Paciano Remalante
- Respondent
- Cornelia Tibe
- Citation
- G.R. No. 59514
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Cortes, J.
- Decided
- February 25, 1988
Summary
This case involves a property ownership dispute over six parcels of land between Paciano Remalante and Cornelia Tibe. Tibe claimed Remalante fraudulently obtained the properties by deceiving her into signing transfer documents he represented as bail bonds, and by forging her signature on a deed of sale. The trial court split the properties, awarding three to each party. However, the Court of Appeals reversed this decision, awarding all six parcels to Tibe after finding that the original owner Silvino Alminario never sold three parcels to Remalante, and that Tibe was fraudulently deceived regarding the remaining three parcels due to her illiteracy. The Supreme Court affirmed the Court of Appeals, emphasizing that factual findings are conclusive absent exceptional circumstances, and rejecting Remalante's legal arguments about double sale and the parol evidence rule. The decision reinforces protection of illiterate parties in contracts and the principle that fraud vitiates consent.