GASATAN, KIMBERLY ROSE BSA-1

Title: Cheng v. Court of Appeals

G.R. No. 144169
Date: October 17, 2001
Facts:
 The case revolves around a dispute between the petitioner, Chung Fu Cheng, and the
respondent, the Court of Appeals (CA).
 Cheng filed a complaint for specific performance and damages against the spouses Jaime
and Norma Tan.
 Cheng alleged that the spouses Tan executed a Deed of Sale in his favor over a parcel of
land, and he had fully paid the purchase price.
 Despite his full payment, Cheng claimed that the spouses Tan refused to deliver the
Transfer Certificate of Title (TCT) in his name.
 The trial court ruled in favor of Cheng, ordering the spouses Tan to execute the necessary
documents to transfer the title in Cheng’s name.
 The spouses Tan appealed the decision to the Court of Appeals.
Issue:
Whether the Court of Appeals erred in reversing the trial court’s decision and dismissing
Cheng’s complaint for specific performance.
Ruling:
The Supreme Court (SC) upheld the decision of the Court of Appeals.
Reasoning:
 The SC agreed with the CA that Cheng failed to establish his entitlement to the relief of
specific performance.
 Cheng’s main evidence, the Deed of Sale, lacked the requisite notarization, making it a
mere private document that cannot be given evidentiary value.
 The SC also noted that Cheng failed to provide proof of full payment of the purchase
price.
 Moreover, Cheng's claim that the spouses Tan refused to deliver the TCT was not
substantiated by evidence.
 In light of these deficiencies in Cheng's evidence, the SC ruled that the trial court's
decision in favor of Cheng was not supported by the law and jurisprudence.
Conclusion:
 The Supreme Court affirmed the decision of the Court of Appeals, which reversed the trial
court's ruling in favor of Cheng. The case was dismissed for failure to prove entitlement to
specific performance.