G.R. No. 194189 - Almeda vs. Heirs of Almeda

The case involves the heirs of Venancio Almeda and Leonila Laurel-Almeda, who were married and had nine children, including Ponciano, Rafael, Emerlina, Alodia, Leticia, Norma, Benjamin, Severina, and Rosalina.
Petitioners (Rafael, Emerlina, Alodia, Leticia, Norma, and Publio Tibi) are among the children or spouses thereof, asserting their status as the only legal heirs of their parents who died intestate.

On May 19, 1976, a Power of Attorney was executed by the elderly spouses Venancio and Leonila, granting Ponciano, among others, the authority to sell the parcels of land covered by Original Certificates of Title (OCT Nos. O-197 and O-443).
The properties described included multiple parcels with detailed breakdowns:

OCT No. O-197 encompassed four lots (Lot 10, Lot 17, Lot 30, and Lot 32) with a combined area of approximately 95,205 square meters.
OCT No. O-443 covered Lot 9, measuring around 33,946 square meters.

Venancio died on February 27, 1985, and Leonila on April 3, 1993. Shortly after Leonila’s death, on April 17, 1993, certain heirs filed a notice of adverse claim with the Register of Deeds over the parents’ properties.
On October 10, 1996, petitioners filed a Complaint for Nullity of Contracts, Partition of Properties and Reconveyance of Titles with Damages (Civil Case No. TG-1643) before the RTC of Tagaytay City. The complaint was directed against Ponciano, his wife Eufemia, the Register of Deeds, and included the unwilling plaintiffs (Ponciano’s heirs/substitutes: Cesar Santos, Rosana Santos, Norman Santos, and Ferdinand Santos).

Petitioners alleged that Ponciano manipulated the transaction by taking advantage of his status as the eldest child to cause the simulation and alleged forgery of critical documents.

The first document in question was the Deed of Absolute Sale dated June 9, 1976, involving Lot 30, executed by Ponciano as attorney-in-fact on behalf of his parents, transferring the property in favor of third parties (Julian Y. PabiloAa, Virginia Go, Gemma Tan Ongking, Arthur C. Chua and Lee Hiong Wee).
The second and more crucial document was the Deed of Absolute Sale dated October 3, 1978, which purportedly transferred the remaining lots under OCT No. O-197, Lot 9 under OCT No. O-443, and additional lots with no technical description for a total price of P704,243.77.

Petitioners contended that their parents did not sign the 1978 Deed, or if they did, it was executed without an understanding of its consequences, and that they did not receive adequate consideration.
Additional allegations included that Ponciano withheld the existence of the 1978 Deed from the other heirs and that when petitioners demanded a partition, he merely promised to perform it at an unspecified later time.

The lone testimony of Emerlina, which was ambiguous regarding whether the signatures on the 1978 Deed were those of their parents or forged.
Other documents such as an Agreement to Sell dated November 9, 1976 and a Deed of Sale with Mortgage dated November 11, 1977, which were later superseded by the 1978 Deed.

Respondents (Ponciano and, after his death, his wife and children) asserted that the 1978 Deed was genuine, that the transactions were for valuable consideration, and accused petitioners of having unclean hands by themselves possibly fabricating evidence.
The RTC of Tagaytay City, after reviewing the notarized documents and the evidence presented, dismissed the complaint on September 2, 2004. This dismissal was later affirmed by the Court of Appeals on May 25, 2010, which also rejected petitioners’ Motion for Reconsideration dated October 13, 2010.

Petitioners later argued defects in the notarization of the 1978 Deed, pointing to its acknowledgment by a notary in Makati City despite the properties being located in Tanauan, Batangas, and questioned the presence of proper identification.
Other contentions included claims of mental incapacity of their parents due to advanced age and alleged undue influence by Ponciano, as well as arguments regarding unconscionably low selling price when compared to a later transaction involving Lot 30.

Filing of the complaint in 1996, subsequent adverse claim filing by heirs in 1993, and the issuance of transfer certificates based on the disputed documents.
Dismissal by the RTC in 2004, denial of motion for reconsideration in 2005, appellate decision in 2010, and ultimately the petition for review on certiorari before the Supreme Court.

Whether petitioners proved by clear, strong, and conclusive evidence that the 1978 Deed was forged, simulated, or procured by undue influence.

Whether the differences in the signatures, as opposed to their similarities, were sufficient to establish forgery.
Whether reliance on uncertain and self-serving testimony (in particular, Emerlina’s ambiguous statements) could overcome the presumption of authenticity.

Whether petitioners discharged their burden to overcome the presumption of due execution and regularity of a notarized document.

Whether the presumption attached to notarized deeds was appropriately rebutted by presenting evidence that the execution was flawed or the signatures were not genuine.

Whether petitioners successfully established ancillary claims, including the absence of adequate consideration, the incidence of undue influence, and the lack of capacity of their parents to contract due to advanced age or infirmities.

Whether the alleged defects in notarization (such as the issue of jurisdiction with the notary’s territorial limits and absence of proper identification) were properly raised and timely presented, or if they should be dismissed as new theories not contested below.