G.R. No. 191278 - Municipality of Sta. Maria, Bulacan vs. Buenaventura

The respondent, Carlos A. Buenaventura, claimed ownership over a parcel of land in Barangay Guyong, Sta. Maria, Bulacan, documented by Transfer Certificate of Title (TCT) No. T-61427(M).
The respondent alleged that without his knowledge or consent, the petitioners – comprising the Municipality of Sta. Maria, Bulacan, its then-Mayor Bartolome R. Ramos, and members of the Sangguniang Bayan – took possession of a portion of his land and constructed a road on approximately 998.75 square meters of the property.

Upon discovery, the respondent demanded the removal of the road by writing to Mayor Ramos.
Subsequent meetings between the respondent and Mayor Ramos led to the drafting of a memorandum of agreement (MOA), wherein the respondent consented to the petitioners’ use of the subject property until 2004, after which the petitioners were to restore the property to its original condition.
The draft MOA was submitted to the Sangguniang Bayan (SB) of Sta. Maria but was rejected by the SB in Kapasiyahan Bilang 2002-112, as its provisions appeared to benefit only the respondent, thereby questioning the mayor’s authority to sign.

The respondent filed a complaint for a sum of money and damages, seeking reasonable rent from the time the road was constructed until the property was restored and returned to him.
The petitioners filed a Motion to Dismiss, arguing that the land on which the road was built actually belonged to Barangay Guyong through a notarized Deed of Donation executed by the respondent.
The Regional Trial Court (RTC) denied the respondent's complaint on the basis that the Deed of Donation, being a public document, was presumed valid and was not subject to dispute in the present proceeding, except through a specific annulment process.

On September 18, 2007, the RTC rendered a decision dismissing the respondent’s complaint, holding that the petitioners acted in good faith based on the valid notarized Deed of Donation.
The respondent appealed to the Court of Appeals (CA), which on October 26, 2009, reversed the RTC decision by finding that:

The petitioners failed to prove that the land in question was the same as that covered by the Deed of Donation.
The respondent presented convincing evidence, by preponderance, that his signature on the deed was forged.

The petitioners’ motion for reconsideration was denied in the CA Resolution dated February 2, 2010.

The CA noted significant discrepancies between the respondent’s signature as shown in the deed of donation and those in his verification/certification documents accompanying his complaint and earlier correspondence.
The Kapasiyahan Bilang 2002-112 further supported the respondent's claim by indicating an agreement that presupposed his ownership, which would not have been necessary if the property had been donated to Barangay Guyong.
Ultimately, the evidence led to the establishment that the Deed of Donation was based on a forged signature and was therefore ineffectual as the basis of the petitioners’ actions.

Whether the notarized Deed of Donation, being a public document, is automatically presumed valid until nullified in a separate proceeding.
Whether such presumed validity can be challenged when evidence of forgery is present.

Whether the burden of proof lies on the petitioners to demonstrate that the Deed of Donation is authentic and that the property in dispute is indeed the portion donated.
Whether the respondent sufficiently discharged his burden by demonstrating, through visual and comparative evidence, that his signature on the Deed was forged.

Whether the municipality's act of constructing the road on the disputed property constitutes bad faith, given the presence of a notarized Deed of Donation.
Whether the petitioners should be held liable for unauthorized taking of the property and consequently be required to pay just compensation and exemplary damages.