G.R. No. 188395 - Heirs of Bucton vs. Spouses Go

The subject property is a parcel of land measuring 6,407 square meters in Lapasan, Cagayan de Oro City.
Originally registered under TCT No. T-9830 in the name of Felix M. Bucton and his wife Nicanora Gabar.
The property was later re-registered under TCT No. T-34210 in the names of Spouses Gonzalo and Trinidad Go.

In March 1981, Gonzalo Go contacted Felix claiming he had purchased the subject property via a person named Benjamin Belisario, who allegedly acted as the attorney-in-fact for Felix.
Felix later discovered that the duplicate certificate of title was lost and ended up in the hands of Belisario and two others (Josefa Pacardo and Salome Cabili), who were allegedly involved in a conspiracy to deprive him of his property rights.
A Special Power of Attorney (SPA), purportedly signed by the Spouses Bucton on February 27, 1981, was used by Belisario to execute a Deed of Absolute Sale on March 2, 1981 in favor of the Spouses Go.
Based on the SPA, the Registry of Deeds canceled the original title in Felix’s name and issued a new title to the Spouses Go.

After Felix’s death, his intestate heirs (Nicanora, Erlinda Bucton-Eblamo, Agnes Bucton-Lugod, Wilma Bucton-Yray, and Don Bucton) filed a complaint seeking annulment of the SPA, deed of sale, and the new title, as well as recovery of ownership and possession of the property.
The Heirs alleged that the signatures on the SPA were forged, contending that if the SPA was spurious, then no valid title was conveyed to the Spouses Go.
The Spouses Go, in their answer, asserted that they were innocent purchasers for value and that under the Torrens system, the certificate of title is conclusive unless there is apparent suspicion or defect.

The RTC of Misamis Oriental, Branch 17, eventually dismissed the Heirs’ complaint on the grounds of laches and prescription, noting that the Heirs delayed in taking legal action from the discovery of the alleged fraud in 1981 until 1996.
The Court of Appeals affirmed the RTC’s decision, rejecting the evidence on forgery and upholding that the Spouses Go were innocent purchasers who had relied on the certificate of title.

Testimony was given by an expert witness, Eliodoro Constantino of the NBI, who noted significant differences in the signature of Felix on standard documents compared to the signature appearing in the SPA.
Nicanora, who had intimate knowledge of Felix’s signature from a long marital relationship, testified that the signature in the SPA was not that of her late husband.
The evidence also included documentary and circumstantial proofs of the chain of events, including a previous criminal case filed by Felix for falsification of public document against Belisario, Pacardo, and Cabili.

Whether the Court of Appeals erred in ruling that the signatures of the Spouses Bucton on the SPA were not forged.

Examination of whether the methods and comparisons used to assess the authenticity of the signature were adequate.
Consideration of the expert testimony and direct evidence from Nicanora regarding the genuineness of the signature.

Whether the Court of Appeals erred in finding that the Spouses Go are innocent purchasers for value.

Assessment of the circumstances surrounding the transaction, especially the fact that the Spouses Go dealt with an agent rather than the registered owner.
Determination of whether the actions of the Spouses Go conformed to the expected prudence and inquiry required of a purchaser under the Torrens system.

Whether the Court of Appeals erred in holding that the action of the Heirs of Felix is barred by laches and prescription.

Inquiry into whether the delay by the Heirs in raising the fraud issue undermines their claim.
Evaluation of whether possession under a spurious title could be considered for calculating prescription and laches under the applicable law.