G.R. No.

200383 March 19, 2018

Norma M. Diampoc, petitioner, vs. Jessie Buenaventura and the Register of Deeds of the City of
Taguig, respondents.

Del Castillo, J.

Norma and her husband, the Diampocs, filed a complaint for annulment of deed of sale and
recovery of duplicate original copy of title, with damages, against Buenaventura.

FACTS:

The Diampocs alleged that they owned a parcel of land, and Buenaventura, a friend, asked to
borrow the owner’s copy of the certificate title of the land to be used as security for a loan she wished to
secure. They acceded, on the condition that she should not sell the property and that she should give
them a portion of the amount out of the loan proceeds. Buenaventura allegedly caused them to sign a
folded document without giving them the opportunity to read its contents. They soon found out that
Buenaventura became the owner of one-half portion of the property by virtue of a supposed deed of sale
in her favour.

ISSUE:

Is there a valid contract of sale between the parties?

RULING:

The Supreme Court ruled that there was a valid contract of sale. It is a well settled rule that the
deed of sale suffering from defects relative to its notarization does not invalidate the transaction, but
merely reduces the evidentiary value of a document to that of a private document. Although Article 1358
of the Civil Code requires that the form of a contracts that transmits or extinguishes real rights over
immovable property should be in public document, the sale is nevertheless valid and binding, for the
formalities required is not essential for the validity of the contract but is simply for its greater efficacy or
convenience. The Court of Appeals even found that the Diampocs received an amount in full consideration
for the sale.

Moreover, the Diampocs conceded that there was such a deed of sale, but they were only induced
to sign. The document was folded according to Norma when she signed, and when her husband signed
the same, it was dark. The failure to observe the care and circumspect expected of them precludes the
courts from lending a helping a hand and must bear the consequences from their negligence. One who
signs a contract is presumed to know its contents has been applied even to illiterate persons such that
they are negligent if they fail to have the contract read to them. One’s failure to obtain an understanding
of a contract is such gross negligence as will estop him from avoiding it on the ground that he was ignorant
of its contents.

The Court did not relieve the Diampocs from the obligations they voluntarily assumed all because of
disastrous deals or unwise investments.

DOCTRINE:
 Formalities required in a contract is not essential for the validity of the contract but is simply for
its greater efficacy or convenience.

One’s failure to obtain an understanding of a contract is such gross negligence as will estop him
from avoiding it on the ground that he was ignorant of its contents.