G.R. No. 174445 ; February 15, 2012
SPOUSES WILLIAM GUIDANGEN and MARY GUIDANGEN, Petitioners, vs. DEVOTA B. WOODEN, Respondent.

FACTS

Respondent Devota Wooden filed a complaint to compel petitioners, the Spouses Guidangen, to execute a registrable deed of sale over a house located at a PNP barracks. She alleged that she and her deceased husband, Nestor, bought the house from petitioners in 1994-1995 for ₱60,000.00, evidenced by a private document. She claimed this document was taken by petitioner Mary Guidangen when she processed Nestor’s death benefits. Respondent presented witnesses, including former tenants, who testified they paid rent to her and that Mary had informed them the house was sold.
Petitioners denied the sale. They asserted they built the house, lived there until 1988, and later allowed their nephew Nestor and respondent to occupy it rent-free. They presented a tax declaration and tax receipts in Mary’s name as proof of ownership. They argued the payments received from the Wooden spouses were for rentals and that the SALN listing the property under Nestor’s name was prepared by Mary merely to facilitate his promotion application.

ISSUE

Whether the Court of Appeals erred in ordering the petitioners to execute a deed of sale in favor of the respondent based on a finding that a perfected contract of sale existed between the parties.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the Regional Trial Court’s decision declaring petitioners as the owners. The Court held that respondent failed to prove the existence of a perfected contract of sale by preponderance of evidence. A contract of sale requires a meeting of minds on the object and the price. Respondent’s evidence was weak and inconsistent; she admitted she was not present during the alleged execution of the sale document, was not a signatory, and did not actually see Mary take the document. Her claim relied heavily on the lost private document, which was not sufficiently proven.
Conversely, petitioners’ evidence of ownership—tax declarations and receipts—remained uncontroverted. The Court emphasized that the plaintiff must rely on the strength of her own evidence, not on the weakness of the defendant’s. Respondent’s claim was further undermined by the fact that the property, being part of a PNP barracks, might be part of the public domain, making its alienation potentially void. The CA’s reliance on the SALN was misplaced, as it was not conclusive proof of ownership but merely a declaration for a specific administrative purpose. Thus, no perfected sale was established to justify compelling the execution of a deed.