Professional Documents
Culture Documents
Logrosa vs. Spouses Azares
Logrosa vs. Spouses Azares
Facts: Petitioner Logrosa alleged that he, together with the respondents are co-owners of eight
(8) parcels of lands the Transfer Certificates of. The TCTs all indicate that petitioner Logrosa,
together with the respondents, are co-owners of the subject properties.
Petitioner Logrosa alleged that in 1987, the original owner of the subject properties, one
Benjamin A. Gonzales, sold the subject properties collectively to petitioner Logrosa and the
other respondents. The records show that a notarized Deed of Absolute Sale was executed by
the parties, bearing the signatures of Gonzales, petitioner Logrosa, respondents Cleofe, Nelson,
Bonifacio, and Abundio.
Respondents Sps. Azares contended that while it may be true that petitioner Logrosa's name
appeared in the titles of the properties aforementioned, however, they belied petitioner
Logrosa's claim that he is a co-owner of the same, as he never contributed as to its acquisition
and never contributed for their maintenance, much less paid the taxes due thereon.
They further alleged that petitioner Logrosa, being their cousin, used to work for them as their
trusted laborer together with the other respondents at their gold mining tunnel. They also
allowed petitioner Logrosa to construct his house upon condition that petitioner Logrosa would
pay and reimburse them for all his expenses thereto when petitioner Logrosa's finances allow.
It is the main contention of respondents Sps. Azares that despite the inclusion in the documents
of title of petitioner Logrosa and the other parties.
Held: No. It is a fundamental principle in land registration that the certificate of title serves as
evidence of an indefeasible and incontrovertible title to the property in favor of the person whose
name appears therein. It becomes the best proof of ownership of a parcel of land. Such
principle of indefeasibility has long been well-settled in this jurisdiction and it is only when the
acquisition of the title is attended with fraud or bad faith that the doctrine finds no application. In
the instant case, there is no accusation whatsoever that petitioner Logrosa was included as co-
owner in the TCTs through means of fraud or bad faith.
Aside from the foregoing, it is also not disputed by any party that a duly notarized Deed of
Absolute Sale was executed by all the parties, wherein it clearly states without ambiguity that
one of the vendees of the subject properties is petitioner Logrosa. It must be stressed that
respondents Sps. Azares do not deny whatsoever that petitioner Logrosa is a co-vendee under
the Deed of Absolute Sale.
The Court has previously held that a document evidencing a sale transaction, such as a deed of
sale, which is duly notarized is considered a public document and therefore enjoys the
presumption of validity as to its authenticity and due execution.
It is not disputed that petitioner Logrosa possesses a portion of the subject property with no
opposition by the other parties, aside from respondents Sps. Azares, who disclaimed petitioner
Logrosa's status as co-owner only after more than two decades since the execution of the Deed
of Absolute Sale, and only as a mere reaction to the Complaint for Partition filed by petitioner
Logrosa.
Hence, with the strong legal presumption created by the eight certificates of title and duly
notarized Deed of Absolute Sale that petitioner Logrosa is a co-buyer and co-owner of the
subject properties, the burden to prove otherwise was shifted to respondents Sps. Azares.
From the evidence on record, the Court finds that respondents Sps. Azares have not
successfully hurdled this burden.