G.R. No. 189871 - Nacar vs. Gallery Frames

Virginia D. Calimag (petitioner) and Silvestra N. Macapaz (Silvestra) were co-owners of a property located at No. 1273 Bo. Visaya Street, Barangay Guadalupe Nuevo, Makati City, with a total area of 299 square meters.
The property was registered under Transfer Certificate of Title (TCT) No. 183088 in the names of Virginia and Silvestra.
Respondents Anastacio P. Macapaz, Jr. and Alicia Macapaz-Ritua are children of Silvestra’s brother, Anastacio Macapaz, Sr., and Fidela O. Poblete Vda. de Macapaz.
Fidela had an Adverse Claim annotation on TCT No. 183088 over a 49.5 sq m portion of the property.

Silvestra died on November 11, 2002, without issue.
On January 18, 2005, a Deed of Sale was allegedly executed wherein Silvestra sold her 99-sq-m portion to petitioner for P300,000.
Consequently, on July 7, 2005, TCT No. 183088 was cancelled, and TCT No. 221466 was issued in petitioner’s name based on the January 18, 2005 deed of sale.
The documents submitted for cancellation included an affidavit (July 12, 2005) by petitioner and Silvestra stating that Fidela’s adverse claim was legally ineffective due to lack of signature by the Deputy Register of Deeds.
Fidela died on September 16, 2005.

On December 15, 2005, respondents filed a criminal complaint against petitioner for falsification of public documents; these charges were later dismissed.
On March 2, 2006, respondents filed a civil action for annulment of the deed of sale and cancellation of TCT No. 221466 with damages against petitioner and the Register of Deeds.
Petitioner countered, claiming respondents were illegitimate heirs without legal capacity to sue based on Article 992 of the Civil Code, which excludes illegitimate children from inheriting intestate from legitimate relatives.

The RTC ruled in favor of respondents on September 28, 2007.
It declared the January 18, 2005 Deed of Sale null and void, as Silvestra had died three years prior to its execution.
Ordered cancellation of TCT No. 221466 and reinstatement of TCT No. 183088 with all liens and encumbrances, including Fidela’s adverse claim.
Ordered petitioner to pay moral damages (P100,000), exemplary damages (P100,000), attorney’s fees (P50,000), plus costs of suit.
Dismissed petitioner’s counterclaim.
On legal capacity, the RTC recognized respondents as legal heirs by proving the valid marriage of Anastacio, Sr. and Fidela through marriage certificate and birth certificates of respondents indicating parentage.

Petitioner appealed, arguing respondents lacked legal personality to sue due to their alleged illegitimacy.
On October 20, 2009, the CA affirmed the RTC decision with modification, reducing damages to P50,000 for moral and exemplary damages each.
The CA upheld the finding that the deed of sale was forged and respondents are legitimate children based on credible proof of marriage and cohabitation.
The CA cited the marriage contract, canonical certificate of marriage, and respondents’ birth certificates as evidence, rejecting petitioner’s claim over lack of valid marriage license.
Petitioner’s motion for reconsideration was denied on April 5, 2010.

Petitioner maintained respondents were illegitimate and had no right or capacity to sue.
Petitioner challenged the authenticity and admissibility of documents purportedly proving marriage between Anastacio, Sr. and Fidela, arguing the marriage contract was a mere fax copy and the canonical certificate did not satisfy legal requisites under the Family Code.
Petitioner also contested birth certificates’ efficacy in proving legitimacy, contending they lacked the father’s signature per Supreme Court precedent.
Respondents asserted legitimacy and legal capacity to sue, noting petitioner failed to offer contrary evidence.

Whether the respondents are legal heirs of Silvestra N. Macapaz and thus have the legal capacity to institute the action for annulment of the deed of sale and cancellation of title.

Whether the documents presented by the respondents sufficiently prove the valid marriage of Anastacio, Sr. and Fidela for purposes of establishing the legitimacy of the respondents under Philippine law.

Whether the certificates of live birth of the respondents are competent and sufficient evidence of their legitimate filiation despite the absence of the father’s signature.