Case Digest (G.R. No. 149738)
Facts:
The case involves Quintin B. Belgica as the petitioner and Marilyn Legarde Belgica and Antonio G. Ong as the respondents. The events leading to the case began in 1983 when Quintin and Marilyn purchased a house and lot in Greenfields Subdivision, Novaliches, Quezon City. In 1989, while Quintin was in the United States, Marilyn sold the property to Antonio Ong using a Special Power of Attorney (SPA) that Quintin had executed in her favor. Upon returning to the Philippines, Quintin contested the authenticity of the SPA, claiming that the signature on the document was forged. He sought assistance from the Presidential Action Center, which referred him to the National Bureau of Investigation (NBI) for a signature examination. The NBI's document examiner, Eliodoro M. Constantino, reported significant differences between the questioned signature and Quintin's standard signatures, suggesting forgery.
In response, Quintin filed a complaint for annulment of the deed of sale,...
Case Digest (G.R. No. 149738)
Facts:
Property Purchase and Sale:
- Petitioner Quintin B. Belgica and his wife, respondent Marilyn L. Belgica, purchased a house and lot in Greenfields Subdivision, Novaliches, Quezon City, in 1983.
- While petitioner was in the United States, Marilyn, acting under a Special Power of Attorney (SPA) allegedly executed by Quintin, sold the property to respondent Antonio G. Ong.
Dispute Over SPA Authenticity:
- Upon returning to the Philippines, Quintin questioned the authenticity of the SPA, claiming his signature was forged.
- He sought the assistance of the National Bureau of Investigation (NBI) to examine the signature. The NBI report concluded that the questioned signature differed fundamentally from Quintin’s standard signatures, suggesting it was forged.
Legal Proceedings:
- Quintin filed a complaint for annulment of the deed of sale, cancellation of title, and reconveyance with damages against Marilyn and Ong in the Regional Trial Court (RTC) of Quezon City.
- During the trial, the NBI document examiner testified that the signature was forged, while respondents presented a PNP Crime Laboratory expert who concluded that the signature was genuine.
- The RTC dismissed the complaint, finding the signature authentic. The Court of Appeals (CA) affirmed the RTC decision.
Petition to the Supreme Court:
- Quintin appealed to the Supreme Court, arguing that the SPA was forged and the sale was void.
Issue:
- Whether the Supreme Court can review the factual findings of the lower courts regarding the authenticity of the SPA.
- Whether the signature on the SPA was forged, rendering the sale of the conjugal property void.
Ruling:
The Supreme Court denied the petition and affirmed the decisions of the RTC and CA.
- The Court emphasized that a petition for review under Rule 45 of the Rules of Court is limited to questions of law, not questions of fact. The authenticity of the SPA is a question of fact, which had already been resolved by the lower courts.
- The Court found no compelling reason to overturn the factual findings of the RTC and CA, which were supported by substantial evidence.
- The testimony of the notary public, Atty. Leopoldo Balguma, who confirmed that Quintin signed the SPA in his presence, was given greater weight than Quintin’s mere denial of signing the document.
Ratio:
Finality of Factual Findings:
- Factual findings of the RTC, when affirmed by the CA, are generally final and conclusive. The Supreme Court does not review factual issues unless there are exceptional circumstances, none of which were present in this case.
Expert Testimony and Judicial Evaluation:
- While expert testimony is valuable in determining the authenticity of signatures, judges are not precluded from independently examining the questioned document and making their own determination.
- The RTC and CA properly evaluated the evidence, including the expert testimonies and the original document, and found no basis to conclude that the signature was forged.
Credibility of Notarial Acts:
- The testimony of a notary public, as an officer of the court, carries greater weight than mere denials by a party. Atty. Balguma’s testimony that Quintin signed the SPA in his presence was deemed credible and sufficient to establish the authenticity of the document.
Burden of Proof:
- Quintin failed to provide competent evidence to support his claim of forgery. His reliance on the NBI report, which was based on a photocopy of the SPA, was insufficient to overturn the findings of the lower courts.
Conclusion:
The Supreme Court upheld the validity of the SPA and the sale of the property, ruling that Quintin failed to prove forgery. The decisions of the RTC and CA were affirmed, and the petition was denied.