Case Digest (G.R. No. 125233) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 15, 1980, Augusto Gomez, as Special Administrator of the intestate estate of his late aunt Consuelo Gomez (died November 6, 1979), filed two civil cases before the Regional Trial Court (RTC) of Pasig City (Civil Cases Nos. 36089 & 36090). In Case No. 36089, he challenged two Deeds of Donation Inter Vivos dated April 21, 1979, purporting to donate three parcels of real property to respondents Maria Rita Gomez-Samson, Marcial Samson, and Jesus B. Gomez, as well as to effect the cancellation and reissuance of Transfer Certificates of Title. In Case No. 36090, he attacked additional Deeds of Donation of personal properties (shares of stock, jewelry, two vehicles, cash placements) alleged to have been given to Ariston A. Gomez, Sr. (later substituted by his widow Luz Bayson Gomez and their children, including Ariston B. Gomez, Jr.) on the same date. Petitioner claimed the deeds were forged and their bodies intercalated over Consuelo’s pre-affixed signatures, praying they Case Digest (G.R. No. 125233) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Background
- Petitioner Augusto Gomez, special administrator of the intestate estate of his aunt Consuelo Gomez (deceased November 6, 1979), filed:
- Civil Case No. 36089 (Feb. 15, 1980) against Maria Rita Gomez-Samson, Marcial Samson, Jesus B. Gomez and the Registers of Deeds of Pasig and Marikina, for annulment of two Deeds of Donation of real properties.
- Civil Case No. 36090 (Feb. 15, 1980) against Ariston A. Gomez, Sr. (died during proceedings, substituted by heirs) and Ariston B. Gomez, Jr., for annulment of two Deeds of Donation of personal properties.
- Petitioner alleged that respondents forged Consuelo’s signature and antedated notarials to April 21, 1979, to transfer:
- Three parcels of land in Marikina and Pasig (TCT Nos. 340233, 353818, 268396) to Rita and Jesus.
- Stocks, jewelry, two vehicles, and P200,000 deposit to Ariston Sr. and Jr.
- Defenses and Counterclaims
- Respondents denied forgery, asserted deeds were validly prepared and registered, and that ownership passed inter vivos on April 20, 1979.
- They prayed for moral, compensatory, exemplary damages, attorney’s fees, and costs.
- Trial Court and Court of Appeals Decisions
- RTC Branch 23 consolidated both cases; after trial, it dismissed the complaints (Apr. 8, 1992), and awarded Ariston B. Gomez, Jr. moral damages of ₱1,000,000, exemplary damages of ₱250,000, attorney’s fees of ₱200,000, costs, plus interest.
- On appeal, the Court of Appeals affirmed in toto the RTC decision (Sept. 4, 2002) and denied reconsideration (Nov. 27, 2002).
- Petitioner filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.
Issues:
- Exceptions to binding appellate factual findings:
- Did petitioner validly invoke the exceptions (absurd inference, grave abuse, misapprehension, overlooked facts, contradicted absence of evidence) to warrant Supreme Court review of CA’s factual findings?
- Alleged errors in CA’s decision:
- Crediting PC-INP Document Examiner Cruz over NBI Examiner Torres on:
- Whether the two deeds were typed in one continuous sitting.
- Whether the handwritten signature preceded the typewritten name.
- Misapprehension of facts regarding payment of donor’s tax:
- Whether Consuelo herself paid the tax on October 9, 1979, before her death.
- Erroneous acceptance of Notary Public Jose Sebastian’s credibility and his November 22, 1979 certification.
- Dismissing apparent irregularities on the face of the deeds (paper size, margins, spacing, placement of notarial entries) as mere lapses of a non-lawyer.
- Ignoring unusual circumstances surrounding execution (flight schedule, choice of notary, lack of will, timing of residence certificates) as indicia of fraud.
- Failing to give weight to petitioner’s circumstantial evidence and the NBI expert’s positive findings, and concluding that petitioner did not establish a network of circumstances proving simulation and falsification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)