G.R. No. 175874 - Heirs of Trazona vs. Heirs of Canada

Case Digest (G.R. No. 175874)
Expanded Legal Reasoning Model

Facts:

Parties and Background

Petitioners: Heirs of Cipriano Trazona (including Francisca T. Matbagon, Natividad T. Abadiano, Carlito C. Trazona, and others), who are asserting ownership of the property.
Respondents: Heirs of Dionisio CaAada (including Rosita C. Gersalina, Conception C. Geonzon, Daniel CaAada, among others) and the local government assessors (Provincial Assessor of Cebu and Municipal Assessor of Minglanilla, Cebu).

Property and Ownership History

The subject property is Lot No. 5053-H in Minglanilla, Cebu, covered originally by Tax Declaration No. 07764 and spanning an area of 9,515 square meters.
Cipriano Trazona acquired the property from the government in 1940, took possession, cultivated it diligently, and regularly paid the corresponding taxes.

Emergence of the Controversy

In 1949, adjacent land was purchased by Dionisio CaAada from Pilar Diaz.
Dionisio later encroached on a part of Lot No. 5053-H, an issue that was brought to Cipriano’s attention in 1952, leading to a confrontation before the barangay captain.
In 1956, despite prior refusal to sell the encroached area, Cipriano permitted Dionisio to temporarily build a house on the disputed portion, a structure that remains on the property.

The Disputed Deed and Tax Declarations

A Deed of Absolute Sale dated June 27, 1956, allegedly executed by Cipriano in favor of Dionisio, covered a portion of Lot No. 5053-H.
Petitioners later discovered that Tax Declaration No. 07764 had been cancelled and replaced by Tax Declaration No. 23959 (issued on 24 June 1996) in the name of Dionisio, allegedly based on the contested deed.
A subsequent Deed of Absolute Sale dated April 11, 1953, executed by Pilar Diaz in favor of Dionisio, further complicated the series of transactions by presenting discrepancies in dates and details.

Initiation of Legal Proceedings

On 28 July 1997, petitioners filed a complaint seeking quieting of title, annulment of the deed, cancellation of the disputed tax declaration, recovery of possession and ownership, damages, and the award of attorney’s fees.
Prior conciliation efforts before the Lupon Tagapamayapa failed, prompting the formal judicial action.

Evidence and Testimonies Presented

Petitioners introduced evidence including:

Testimony of Romeo O. Varona, document examiner from the PNP Crime Laboratory, who compared Cipriano’s signature on the assailed deed with standard signatures and found significant discrepancies indicative of forgery.
Documentary evidence highlighting inconsistencies such as the difference in dates (1953 vs. 1935) in the two deeds, irregularities in the residence certificates, and physical differences (color and paper quality) in the deed submitted by the Bureau of Archives.

Respondents countered with:

Testimony by Dionisio’s son, Gorgonio, who claimed personal knowledge of the deed’s execution and emphasized the continued enjoyment of the property’s fruits by respondents.
Arguments asserting that, as a notarized document, the deed carried a presumption of regularity and authenticity despite its antiquity.

Prior Judicial Decisions

The Regional Trial Court (RTC) ruled in favor of petitioners by annulling the assailed deed, ordering the cancellation of Tax Declaration No. 23959, reinstating Tax Declaration No. 07764, and directing respondents to demolish the residential structure on the property along with payment of attorney’s fees and litigation expenses.
The Court of Appeals (CA) reversed the RTC ruling, holding that the notarized deed benefited from a presumption of authenticity, that the document examiner’s analysis was inconclusive given the examination was based on a machine copy, and that respondents’ actual possession of the property validated their claim.

Escalation to the Supreme Court

Petitioners filed a Petition for Review on Certiorari under Rule 45, contesting the CA’s findings, particularly regarding:

The presumption of authenticity of the deed.
The sufficiency of the evidence to demonstrate forgery.
The factual basis for respondents’ possession of the property.
The treatment of attorney’s fees and litigation expenses.

The Supreme Court, after reviewing the evidence and both the RTC and CA decisions, determined that the factual findings of the RTC were well supported, thereby overruling the conclusions of the CA.

Issues:

Presumption of Authenticity of Notarized Documents

Whether the notarized Deed of Absolute Sale should be given a conclusive presumption of regularity despite evidence suggesting anomalies and forgery.

Determination of Forgery

Whether the evidence provided—particularly the expert testimony on signature discrepancies and independent observations—establishes with clear and convincing certainty that the assailed deed is a forgery.

Actual Possession and its Legal Effects

Whether the prolonged possession and tax payment by petitioners constitute definitive evidence of ownership, notwithstanding the existence of the contested deed and subsequent tax declaration issued in favor of Dionisio.

Scope of Review on Certiorari

Whether the issues raised, being largely factual (e.g., the authenticity of the signature and possession of the property), fall outside the typical questions of law that warrant review by the Supreme Court under Rule 45.

Award of Attorney’s Fees and Litigation Expenses

Whether the award for attorney’s fees and litigation expenses granted by the RTC, and later affirmed by the evidentiary findings supporting forgery, is justified.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 175874) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 175874) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 175874)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 175874)
Expanded Legal Reasoning Model