Case Digest (G.R. No. 224076)
Facts:
The case involves the petitioners Soledad E. Dizon, Corazon R. Espinosa, Cynthia R. Espinosa, Jennifer R. Espinosa, Julie R. Espinosa, Gelacio R. Espinosa, Jr., and Joselito R. Espinosa (the heirs of Segundo Espinosa) against respondents Rodrigo G. Tuazon and Estrella M. Tuazon. It stems from a dispute over the ownership of two parcels of land situated in Brgy. Tibag, Tarlac, Tarlac, which are covered by Original Certificate of Title No. 0-279 and Transfer Certificate of Title No. 38284. Segundo Espinosa, the deceased owner, had previously cohabited with Laureana Bondoc, with whom he had a daughter, Estrella. In 1988, petitioner Soledad discussed transferring the properties into their names, to which Segundo agreed. However, Segundo informed them that the titles were held by Estrella and Rodrigo Tuazon, who claimed to have purchased the properties through a Deed of Absolute Sale executed by Segundo in 1985, along with an Affidavit of Non-tenancy and a subsequent Agreement of Su
Case Digest (G.R. No. 224076)
Facts:
- Background of the Parties
- Petitioners are the heirs of Segundo Espinosa, who owned one‑half undivided share in two parcels of land (individually covered by OCT No. 0‑279 and TCT No. 38284) located in Brgy. Tibag, Tarlac.
- After being widowed, Segundo cohabited with Laureana Bondoc and had a child, Estrella Tuazon, who is one of the respondents.
- Transaction and Dispute over the Land
- In 1988, petitioner Soledad Dizon, daughter of Segundo, discussed with her sibling the transfer of the properties in their name.
- They informed Segundo of their desire to transfer title.
- Upon inquiry, Segundo revealed that the titles were already in the names of Estrella and respondent Rodrigo Tuazon.
- Soledad obtained copies of pertinent documents at the Register of Deeds, which included:
- A Deed of Absolute Sale allegedly executed by Segundo in favor of the respondents.
- An Affidavit of Non‑tenancy supporting the transaction.
- In 1990, respondents allegedly prepared an Agreement of Subdivision that appeared to evidence Segundo’s consent and signature.
- Allegations of Forgery and Fraud
- When Segundo was confronted with the documents, he claimed:
- He was deceived by the respondents into executing the transactions.
- His signature on the documents was forged.
- Segundo consulted with Atty. Conrado Genilo, the notary who notarized the documents, who admitted:
- He had merely notarized documents prepared by his secretary.
- He was willing to testify in favor of Segundo.
- Procedural History
- Initially, following inconclusive barangay conciliation, Segundo prepared and signed a complaint for annulment of the questioned documents; however, the filing did not proceed due to his illness and Soledad working abroad.
- After Segundo’s death on 16 October 1995, petitioners (his heirs) filed a complaint for:
- Declaration of nullity of the Deed of Absolute Sale, Affidavit of Non‑tenancy, and Agreement of Subdivision.
- Damages against the respondents.
- Respondents defended their actions by asserting:
- The documents were executed for valuable consideration in connection with Segundo’s mortgage obligation to the Philippine National Bank (PNB).
- Their payments on the mortgage and possession of original documents (e.g., PNB receipts) corroborated the validity of the sale.
- Findings in the Lower Courts
- Regional Trial Court (RTC) Decision
- The RTC found that the signatures on the documents were not genuinely that of Segundo.
- Consequently, the RTC declared all three documents null and void, ordered the cancellation of the titles in respondents’ names, and mandated the restoration of the former titles.
- Petitioners were further required to pay litigation expenses and attorney’s fees.
- Court of Appeals (CA) Decision
- The CA reversed the RTC’s decision.
- The appellate court ruled that petitioners failed to establish forgery by a preponderance of the evidence.
- It gave weight to testimonies by witnesses—including the notary’s secretary and Rodrigo—attesting to Segundo’s signature, and emphasized the presumption of regularity owing to the documents’ notarized form.
Issues:
- Whether the petitioners sufficiently established, by a preponderance of evidence, that Segundo’s signature on the questioned documents was forged or falsified.
- Did the evidence, including expert testimony (the NBI report) and witness accounts, demonstrate that the signatures were not genuinely executed by Segundo?
- Whether the natural variations in a person’s signature (abbreviated vs. full signature) suffice to conclude forgery?
- The extent to which the presumption of authenticity and due execution of notarized documents applies.
- Can the presumption be overcome by the evidence submitted by petitioners?
- Was the evaluation of the handwriting expert’s testimony adequate, considering the varying conclusions on the questioned signatures?
- The proper interpretation of evidentiary documents and testimonies concerning the history of the transaction
- How should conflicting evidence from the barangay proceedings, the documentary evidence, and the testimonies of various witnesses be reconciled?
- Does the existence of PNB receipts and the transfer protocols negate the claims of forgery?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)