G.R. No. 216491 - Heirs of Donton vs. Stier

Petitioners: The heirs of Peter Donton, represented legally by Felipe G. Capulong; respondents: Duane Stier and Emily Maggay.
The dispute concerns a parcel of land located at No. 33 Don Jose Street, Murphy, Cubao, Quezon City, measuring approximately 553.60 square meters (subject property).
The property was originally titled under Transfer Certificate of Title (TCT) No. N-137480 in the name of Peter Donton. The title was later cancelled and transferred under TCT No. N-225996 in respondents’ names.

In June 2001, Peter Donton, while in the United States, discovered respondents had taken possession of the subject property and managed his business there.
Despite demands by Donton’s lawyers for respondents to vacate and cease operations, respondents refused.
Upon returning to the Philippines, Donton learned that respondents allegedly secured ownership by fraudulent means; the original title (TCT No. N-137480) was cancelled and a new title issued in their names (TCT No. N-225996).
Donton filed a complaint for annulment of title and reconveyance with damages, alleging the signature on the Deed of Absolute Sale dated July 16, 2001 was forged. He denied signing or executing the deed, emphasizing he was supposedly in the United States between June 27 and August 30, 2001.
Donton alleged conspiracy between respondents and Registry of Deeds officials, asserting Stier’s status as an American citizen, a non-resident alien barred from owning property in the Philippines.
He prayed for annulment and cancellation of TCT No. N-225996, issuance of a new title in his name, and damages for moral, exemplary, attorney’s fees, and litigation expenses.

An Occupancy Agreement dated September 11, 1995 recognizing Stier’s residence since January 5, 1995.
A loan of ₱3,000,000 granted on July 5, 1997 secured by a mortgage on the property.
A Special Power of Attorney (SPA) dated September 11, 1995, granting Stier authority to sell, mortgage, or lease the property.
A “unilateral contract of sale” dated June 25, 2001, followed by the Deed of Absolute Sale dated July 16, 2001.

Respondents prayed for damages and attorney’s fees in their counterclaim.
During trial, Donton presented expert testimony from Rosario C. Perez, a document examiner, who concluded the signature on the Deed of Absolute Sale was not his.
Perez admitted that the standard signatures used for comparison were provided by the CIDG, and she did not verify their authenticity.
After the death of Peter Donton in 2003, petitioners were substituted as plaintiffs.
Respondents waived their right to present evidence.

On December 14, 2009, the RTC dismissed the complaint citing insufficiency of evidence.
The RTC held the Deed of Absolute Sale, a public and notarial document, carries a presumption of regularity.
The expert testimony of Perez was deemed self-serving and unworthy of probative value due to unverified source documents and lack of court order for examination.
The RTC denied petitioners’ motion for reconsideration, finding failure to prove Stier’s American citizenship beyond a BOI certification and petitioners’ failure to prove other allegations such as Stier’s marital status and Maggay’s incapacity to acquire property.
The RTC found Donton’s claim of absence from the Philippines on the date of the deed’s execution dubious because of his admission of being in the country in late July 2001.

On June 13, 2014, the CA affirmed the RTC ruling, holding petitioners failed to prove forgery by clear and convincing evidence.
The CA noted the notarized deed enjoys the presumption of validity.
It found the immigration stamps insufficient to prove Donton’s absence from the Philippines on July 16, 2001, highlighting no record of entry into the United States.
The CA upheld the RTC’s dismissal of Perez’s expert testimony due to lack of verification of specimen signatures’ origin.
The CA also upheld that petitioners failed to prove Stier’s American citizenship, marital status, and Maggay’s supposed incapacity to buy property.
A motion for reconsideration was denied on January 21, 2015, prompting the filing of the present petition for review.

Whether the Court of Appeals erred in ruling that petitioners failed to discharge their burden of proving forgery of Donton’s signature on the Deed of Absolute Sale and thus failed to justify annulment of title and reconveyance of property with damages.

Whether the Court of Appeals erred in ruling that petitioners failed to prove Stier’s American citizenship and non-resident alien status, which would render the sale to him void under the Constitution.

Whether the alleged incapacity of Maggay to acquire the property has been proven.