Facts:

The case involves Alfredo Chanco, the administrator of the estate of Maximo Madrilejos, as the plaintiff and appellant, against Anacleta Madrilejos and others as defendants and appellees. The events leading to this case began with a document, referred to as Exhibit No. 3, which was claimed to be a receipt executed by Maximo Madrilejos on March 1, 1875, in Azagara, Philippines. The trial court initially found this document to be genuine. However, upon appeal, the plaintiff sought to introduce newly discovered evidence regarding the authenticity of the paper on which the receipt was written. A commissioner was appointed to investigate the date of manufacture of the paper, leading to the examination of Joaquin Samurac, the manager of a paper factory named "La Hispana Americana." Samurac testified that the paper was not produced until after March 1, 1875, and that the watermarks on the paper were exclusive to his factory, which did not start using them until 1880. Addit...

Facts:

1. Background of the Case:
   The case involves a dispute over the authenticity of a document, Exhibit No. 3, which purports to be a receipt executed by Maximo Madrilejos on March 1, 1875, in Azagara, Philippines. The document was presented as evidence in a property dispute between the administrator of Maximo Madrilejos' estate (plaintiff) and Anacleta Madrilejos et al. (defendants).

2. Evidence Presented at Trial:

   • The trial court initially found the document to be genuine, relying on the testimony of a subscribing witness, Silvestre, and Anacleta Madrilejos, who both attested to its execution.
   • The document appeared aged, and the signature of Maximo Madrilejos was claimed to be genuine.

3. Newly Discovered Evidence on Appeal:

   • On appeal, the Supreme Court appointed a commissioner to investigate the paper's origin. Joaquin Samurac, manager of the paper factory "La Hispana Americana," testified that the paper used for the document was not manufactured until after 1875. Specifically, the watermarks ("Papel Catalan" and "F. D. E.") were not used until 1880, and the first shipment to the Philippines occurred in 1881.
   • Additional evidence suggested the paper was chemically treated to appear aged, and the signature of Maximo Madrilejos was likely a forgery.

4. Trial Court's Reluctance:
   The trial judge acknowledged the suspicious circumstances surrounding the document but ruled in favor of its authenticity, citing the testimony of witnesses and the difficulty of reconciling inconsistencies in the evidence.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Authenticity of Documents:
   The authenticity of a document can be challenged based on extrinsic evidence, such as the origin of the materials used (e.g., paper, ink) and expert testimony. In this case, the paper's watermarks and manufacturing timeline provided irrefutable evidence that the document was fabricated.

2. Burden of Proof in Forgery Cases:
   The burden of proving the authenticity of a document lies with the party presenting it. When newly discovered evidence casts reasonable doubt on its genuineness, the court must reevaluate its findings.

3. Judicial Review of Trial Court Decisions:
   Appellate courts have the authority to overturn trial court decisions when new evidence demonstrates a clear error in the original ruling. The Supreme Court emphasized that the trial judge's reliance on witness testimony, despite the suspicious circumstances, was insufficient to uphold the document's authenticity.

4. Equitable Relief in Property Disputes:
   When a document central to a property dispute is proven fraudulent, the rightful owner or administrator is entitled to equitable relief, including possession and control of the property.