G.R. No. L-39201 April 30, 1980
AMPARO MONFORT, petitioner, vs. HON. COURT OF APPEALS (Eighth Division), ASUNCION RODRIGUEZ-LAMATA and EMILIO LAMATA, respondents.

FACTS

Petitioner Amparo Monfort sought the annulment of a Deed of Absolute Sale dated May 15, 1951, covering twelve parcels of land, which she executed in favor of respondents Asuncion Rodriguez-Lamata and Emilio Lamata. She alleged the deed was void for lack of consideration, claiming she was induced to sign it to stop her husband’s financial demands but received no payment. The trial court dismissed her complaint, upholding the deed’s validity and ordering her to pay attorney’s fees and damages. The Court of Appeals affirmed this decision in toto.
During the pendency of her petition for review before the Supreme Court, Amparo Monfort died on February 18, 1978. Her counsel moved to substitute her with her niece, Amparo Garcia Monfort Jalbuena, named as heir in an unprobated will. Respondents opposed, arguing there was no legal representative duly appointed and that other intestate heirs existed. Counsel then alternatively requested time to confer with other potential heirs for substitution.

ISSUE

The primary issue is whether the Supreme Court should affirm the dismissal of the petition for review, thereby upholding the validity of the deed of sale. A secondary procedural issue concerns the substitution of the deceased petitioner.

RULING

The Supreme Court reinstated its original resolution denying the petition for lack of merit, effectively affirming the Court of Appeals’ judgment. The legal logic is anchored on the conclusive nature of factual findings and the strength of written contracts. The respondent appellate court meticulously reviewed the voluminous records and found petitioner’s claim of no consideration utterly unsubstantiated. The deed, a clear and unambiguous public instrument written in Spanish—a language known to the petitioner—expressly stated the consideration: a cash payment, assumption of a bank obligation, and a lifetime pension. Under Article 1370 of the Civil Code, when a contract’s terms are clear, its meaning is determined from its contents alone. A party is bound by a contract they sign; they cannot later deny its stipulations by claiming they did not read it.
To impugn the recitals in a public document, evidence must be clear and satisfactory. The petitioner relied solely on her own uncorroborated testimony, which is insufficient to overcome the legal presumptions of sufficient consideration and the regularity of private transactions. Furthermore, her subsequent acts—signing a clarifying document, reporting capital gains in her tax return, and corresponding with tax authorities about the sale—confirmed the transaction’s validity. Given the finality accorded to the lower courts’ factual findings and the absence of reversible error, the Supreme Court found no basis to disturb the judgment. The resolution of the main case on the merits rendered the procedural question of substitution moot, as the dismissal of the petition is binding on the petitioner’s estate.