G.R. No. 205912 - Gatan vs. Vinarao

Petitioners: Rogelia R. Gatan and her sons, Rizalino Gatan and Ferdinand Gatan (acting as heirs of Bernardino Gatan).
Respondents: Jesusa Vinarao and the spouses Mildred and Nomar Cabauatan.
Subject Matter: A parcel of land in Casibarag Sur, Cabagan, Isabela, originally acquired by spouses Gatan.

Bernardino Gatan, petitioners’ late husband/father, acquired the property which was surveyed and recorded under LMB Form No. 23-37-R (dated October 26, 1964).
After Bernardino’s death (March 19, 2000), disputes arose concerning a portion (around 245 square meters) of this property now referred to as the “subject property.”
Alleged Transaction: A Deed of Absolute Sale dated December 30, 1989, purportedly executed by Bernardino transferring the subject property to respondent Mildred’s parents, Sostones and Jesusa Vinarao, for a consideration of ₱4,000.00.

The petitioners contend that the Deed of Absolute Sale is void and inexistent due to:

Alleged forgery of Bernardino’s signature (claiming he was unschooled and unable to sign by himself).
Lack of valid marital consent, as the document shows the signature of “Aurelia Ramos Gatan” instead of petitioner Rogelia’s authentic name.

It is alleged that petitioner Rogelia’s testimony and the submission of specimen signatures were insufficient to prove the validity of the executed document.
The petitioners further maintain that Bernardino never married a woman named Aurelia Ramos Gatan, asserting that the document was fabricated.

The petitioners initiated a Complaint for Nullity of Document and Recovery of Possession with Damages (Civil Case No. 22-1061) before the Regional Trial Court (RTC) on January 3, 2007.
Respondents countered with evidence showing:

Prior ownership by Pedro Gatan and subsequent actual possession by Carmen Gatan before the spouses Gatan eventually came to own the subject property.
The sale was supported by notarized documentation, tax declarations, and tax receipts confirming continuous payment for real property taxes.

The RTC rendered a Decision on October 1, 2009, dismissing the petitioners’ complaint and upholding the validity of the Deed.
The petitioners appealed, with the Court of Appeals affirming the RTC ruling on September 7, 2012, and dismissing the Motion for Reconsideration on February 11, 2013.

Petitioners raised the issue under Rule 45, reiterating their arguments that the Deed of Absolute Sale was invalid due to alleged forgery and non-consent.
The petition sought the reversal of both the RTC’s decision and the subsequent appraisal by the Court of Appeals.

Whether the Court of Appeals erred in affirming the trial court’s decision upholding the validity of the Deed of Absolute Sale dated December 30, 1989.

Specifically, whether the doubts raised regarding the authenticity of Bernardino’s signature and the absence of proper marital consent warranted reversal.

Whether the petition for review on certiorari, which primarily reiterates arguments and factual issues already resolved, is a proper vehicle for reconsidering factual determinations.

Whether the evidence presented by petitioners—namely, allegations of unschooled signature practices and discrepancies in names—constitutes clear, convincing, and more than preponderant proof to overcome the legal presumption of authenticity attached to a duly notarized document.