G.R. No. 158015 - Bautista vs. Court of Appeals

Petitioner: Laura Morelos Bautista, who purchased the parcel of land from her late uncle, Cesar Morelos.
Respondent: Fernando Morelos, who claims to be the illegitimate child of Cesar Morelos and seeks the annulment of the deed.

The subject property is a parcel of land along Maceda (formerly Washington) Street in Sampaloc, Manila, covering approximately 105 square meters.
Originally owned by the late Cesar Morelos under Transfer Certificate of Title No. 27604, the property was sold via a Deed of Absolute Sale executed on April 5, 1982, notarized by Luis M. de Guzman.
A new title, Transfer Certificate of Title No. 254843, was issued in the name of Laura Bautista following the sale.

Cesar Morelos, who had no children with his wife Rosario Duran (Rosario having died in 1972), executed the sale of the property to his niece, Laura Bautista, during his lifetime. He died on April 15, 1982, just ten days after the deed was executed.
Fernando Morelos, asserting that the decedent’s signature on the deed was forged, filed a complaint in Civil Case No. 83-17900 before the Regional Trial Court (RTC) of Manila, Branch VII, seeking the nullification of the sale and damages.
During the trial, the evidentiary record included:

Testimony by Carmelita Marcelino, the witness to the signing of the deed, attesting that she saw Cesar Morelos and Laura Bautista sign the document.
Expert testimony by Francisco Cruz, Jr. (Chief Examiner of the PC-INP Crime Laboratory Service) contending that the signature on the deed did not match known authentic signatures of Cesar Morelos.
Testimony by Major Braulio Monge (Chief of the Fingerprint Division of the PC-INP) asserting that the thumbmark on the residence certificate attached to the deed differed from previous thumbmarks of the decedent.

The RTC rendered a judgment declaring the deed valid, dismissing both the claims for nullity and the counterclaims for damages.
The Court of Appeals (CA) reversed the RTC’s decision, setting aside the judgment and declaring the deed null and void. The CA ordered the cancellation of the title in Laura Bautista’s name and directed that the property be restored to the estate of Cesar Morelos.

Petitioner Laura Bautista filed a petition for review on certiorari, challenging the CA decision on several grounds.
The petition raised issues regarding the conclusiveness of expert testimonies, the overall validity of the Deed of Absolute Sale, and the legal capacity of Fernando Morelos to seek the annulment of the deed.

Whether the testimonies of expert witnesses, which pointed to discrepancies in the signature and thumbmark of Cesar Morelos, are conclusive enough to nullify a duly executed and notarized Deed of Absolute Sale.
Whether the Deed of Absolute Sale, executed on April 5, 1982, is valid in light of the evidence presented concerning the authenticity of the decedent's signature and thumbmark.
Whether Fernando Morelos possesses the requisite legal personality to seek the annulment of the Deed of Absolute Sale, given his status and the allegations asserted.