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.

Statutes applied

Related cases

Other Philippine cases on the same provisions and issues.

Related research

In-depth Intellegal research on the provisions this case applies.

Search Philippine case law on Intellegal →

By the Intellegal Editorial Board · February 25, 1988

Search Philippine case law on Intellegal →
AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.