**Facts:**
1. **Initial Ownership and Claim:** The subject property, a parcel of land, was originally part of Lot No. 9194 registered under TCT No. 2556 in the names of Ronico and Gloria Lopez’s parents, Severino and Esperanza Lopez, with a total measurement of 261,425 sq. m., located in Barrio Nueva Vista, Ormoc City.
2. **Petitioners’ Action:** Spouses Ronico and Marcelina Lopez, along with Spouses Gloria Lopez Adorza and Nicomedes Adorza, filed a complaint in the RTC for Quieting of Title alleging ownership of an 80,000 sq. m. portion of this land, claimed under TCT No. 28487.
3. **Respondents’ Rebuttal:** Respondents (multiple Potoy and other families) claimed that a portion of the land was sold to Agustin Potoy through a notarized Deed of Absolute Sale, evidenced by an Affidavit of Adverse Claim filed during the transfer to Dionisio Torrevillas and Esperanza Larrazabal, under a subsequent TCT.
4. **RTC Decision:** The RTC ruled in favor of the petitioners, citing a lack of evidence from the respondents regarding the sale’s validity and ordered them to respect the petitioners’ ownership. Attorney’s fees and litigation costs were also awarded to the petitioners.
5. **Appeal to CA:** Respondents appealed the RTC decision to the Court of Appeals (CA), which reversed the RTC’s ruling, upholding the notarized sale document and dismissing petitioners’ complaint, citing the presumption of regularity of the notarized document.
**Procedural Posture:**
1. **RTC Proceedings:** Petitioners filed a complaint for Quieting of Title and the RTC accepted their evidence, finding against the claims of the respondents as unsubstantiated.
2. **CA Decision:** The CA reversed the RTC’s decision, granting the appeal in favor of respondents by dismissing the complaint, acting on the presumption that the notarized Deed of Absolute Sale was valid.
3. **Supreme Court Review:** Dissatisfied, petitioners filed a Petition for Review on Certiorari to the Supreme Court under Rule 45, questioning the CA’s decision.
**Issues:**
1. Whether the Deed of Absolute Sale notarized and presented by respondents disproves petitioners’ claim of ownership due to its presumption of regularity.
2. Whether the denial by the petitioners, supported by the RTC, regarding their alleged signatures on the deed was sufficient to overturn the CA’s presumption of the document’s validity.
**Court’s Decision:**
1. **Presumption of Regularity:** The Supreme Court upheld the CA’s decision, emphasizing the presumption of regularity attributed to duly notarized documents. The Court underscored that the petitioners failed to provide clear and convincing evidence to overcome this presumption, especially since they did not assert that the signatures were forged.
2. **Credibility of Notary Public’s Testimony:** The testimony of Notary Public Demosthenes Tugonon, who notarized the deed, was given greater weight than the mere denial from the petitioners. Tugonon’s familiarity with the signatories and their presence at the time of notarization corroborated the sale’s legitimacy.
3. **Possession as Evidence of Sale:** Continuous possession by the respondents from 1969 further evidenced the validity of the transaction, contributing to the dismissal of the petition.
**Doctrine:**
1. **Presumption of Regularity for Notarized Documents:** A notarized instrument holds the presumption of regularity and validity unless clear, strong, and convincing evidence is presented to disprove it.
**Class Notes:**
– **Action to Quiet Title:** Requires both showing a genuine title and disproving any adverse claim.
– **Notarization:** Provides a presumption of validity unless contested with substantial evidence.
– **Burden of Proof:** Lies upon the party challenging a notarized document to provide credible evidence beyond mere denial.
**Historical Background:**
The case reflects longstanding legal principles reaffirming the integrity of notarized documents in property disputes and underscores the continuity of legal interpretations regarding property transfers and registration under Philippine law. The significance of possession and the role of notaries public are entrenched in property conveyance practices within the country’s legal history.
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