G.R. No. L-5640 - Goitia vs. Chartered Bank of India

Norma B. Domingo and her husband, Valentino Domingo, were the registered owners of Lot 19, Block 1, in Cristina Subdivision, Concepcion, Marikina, as evidenced by Transfer Certificate of Title No. 53412.
The petitioner, Norma B. Domingo, discontinued the construction of her house on the lot, citing lack of financial support from her husband, and subsequently decided to dispose of the property.

Flor Bacani, a friend of the petitioner, volunteered to act as her agent in selling the lot.
The petitioner delivered the original owner's copy of Transfer Certificate of Title No. 53412 to Bacani.
The title later was reported as lost; during the petition for reconstitution, the petitioner submitted receipts of payments for real estate taxes and signed what she remembered as a record of exhibits at Bacani’s request.
Bacani eventually ceased to appear, leaving the petitioner without further guidance.

On November 1, 1994, petitioner Norma Domingo visited the lot only to observe that construction had commenced by the respondents, the Robles family.
Verification with the Register of Deeds revealed that the reconstituted Transfer Certificate had been cancelled following the registration of a Deed of Absolute Sale, dated May 9, 1991, executed by the Domingo spouses as sellers and Yolanda Robles (acting also for the minor Robles) as buyer.
A new title, Transfer Certificate of Title No. 201730, was subsequently issued on June 10, 1991 in the name of respondent Robles.

The petitioner claimed she had not met any of the respondents nor had she signed any sale agreement of the property.
She alleged that the Deed of Absolute Sale was a forgery, contending that her and her husband’s signatures were fraudulently used to transfer the property.
Based on the forgery claim, the petitioner sought the nullity of the sale and the reconveyance of the property.

Respondents contended that they were buyers for value and in good faith.
They alleged that the lot was offered to them by Bacani in his capacity as agent, and during the sales process they were presented with:

They also claimed that after purchasing, they contracted to sell the lot to third parties (spouses Danilo and Herminigilda Deza) for P250,000.00.
Additionally, respondent Yolanda Robles obtained guardianship authority over her minor children to further legitimize and secure the transaction.

The Regional Trial Court (RTC), Branch 272 of Marikina, rendered a decision dismissing the petitioner’s complaint on May 13, 1996.
The Court of Appeals (CA) later affirmed the RTC decision, holding that:

Respondents were purchasers in good faith and for value.
The sale was accomplished through a duly authorized agent (Bacani) who presented the original Certificate of Title and necessary receipts.
The reconstituted title was free of liens and adverse interests.

Despite the petitioner’s allegation of forgery, the CA found no evidence to undermine the apparent authenticity of the signatures or contest the good faith of the respondents.

Whether the petitioner is entitled to reverse the effects of the sale on account of alleged forgery of her and her husband’s signatures in the Deed of Absolute Sale.
The determination of who qualifies as a purchaser in good faith under the circumstances, particularly in light of the evidence supporting the validity of the transaction.