Sie sind auf Seite 1von 1


The Dela Cruz sisters were the aunts of Dolores Rongavilla. They borrowed P2,000 from the Rongavillas
to have their rooftop repaired. Later, petitioners went back to their aunts to have them sign a contract.
Taking advantage of their lack of education, the sisters were made to believe that such document,
typewritten in English, was just for the acknowledgment of their debt. After four years, petitioners asked
their aunts to vacate the land subject to litigation claiming that she and her husband were the new
owners. After verifying with the Registry of Deeds, the aunts were surprised that what they have signed
was actually a deed of sale. Their land title was cancelled and the ownership was transferred to their
nephews. The land was mortgaged with the Cavite Development Bank.


Was the deed of sale void?


Yes. While petitioners claimed they were regularly paying taxes on the land in question, they had no
second thoughts stating at the trial and on appeal that they had resorted to doctoring the price stated in
the disputed Deed of Sale, allegedly to save on taxes. While it is true that public documents are
presumed genuine and regular under the Rules of Court, this presumption is a rebuttable presumption
which may be overcome by clear, strong and convincing evidence.