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	GR No. 133895 2001-10-02	ZENAIDA M. SANTOS v. CALIXTO SANTOS QUISUMBING, J.
Nowhere in the Civil Code, however, does it provide that execution of a deed of sale is a conclusive presumption of delivery of possession. The Code merely said that the execution shall be equivalent to delivery. The presumption can be rebutted by clear and convincing evidence.[16] Presumptive delivery can be negated by the failure of the vendee to take actual possession of the land sold.[17]