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Juan Dela Rama, et al. Vs. Oscar Papa and Ameurfina Papa

JUAN DELA RAMA and EUGENIA DELA RAMA, Petitioners, versus OSCAR PAPA and AMEUERFINA PAPA, Respondents.

G.R. No. 142309 | 2009-01-30

D E C I S I O N


Tinga, J.:

This petition allows us to reiterate some of the basic rules concerning the notarization of deeds of conveyance involving real property. Such rules are important because an improperly notarized document cannot be considered a public document and will not enjoy the presumption of its due execution and authenticity.

I.

Petitioner spouses Juan and Eugenia dela Rama were the registered owners of a parcel of land situated in Calamba, Laguna, covered by Transfer Certificate of Title (TCT) No. 91166 issued by the Registry of Deeds of Laguna. The property was acquired for P96,000.00 by way of sale from Canlubang...