G.R. No. 163271 - Spouses Bernales vs. Heirs of Sambaan

Petitioners: Spouses Patricio and Myrna Bernales, who claim title to the disputed land.
Respondents: Heirs of Julian Sambaan (including Emma S. Felicilda, Anita S. Sambaan, Violeta S. Dadsanan, Absalon Sambaan, Agustine Sambaan, Editha S. Manguiran, Grace S. Nitcha, Clodualdo Sambaan, Gina Sambaan, and Fe S. Yap).
The disputed property is located at Bulua, Cagayan de Oro City and is described in detail on Transfer Certificate of Title (TCT) No. T-14202, covering 3,643 square meters.

Julian Sambaan, originally the registered owner, held the property under TCT No. T-14202, issued on March 8, 1972. The title and lot description indicate the property was part of a subdivision, segregated from a larger Lot No. 5947.
Julian, married to Guillerma Saarenas-Sambaan, allegedly executed a Deed of Absolute Sale dated December 7, 1970, transferring the property to petitioners. This deed later became the subject of dispute.

In 1975, following an ambush which left Julian wounded, he summoned his children to express his last wishes, including that the children should redeem the mortgaged property from Myrna and her husband.
In 1982, respondent Absalon, one of Julian’s children, offered to redeem the property; however, petitioners allegedly refused, claiming the property was being used as a tethering area for cattle.
In January 1991, respondents discovered that the property title had been transferred to the petitioners. They subsequently obtained a copy of the disputed Deed of Absolute Sale and, upon examination by the National Bureau of Investigation (NBI), found that the signatures of Julian and Guillerma were forged.

Respondents, together with their mother Guillerma, instituted a Complaint for Annulment of the Deed of Absolute Sale and Cancellation of TCT No. T-14204 on April 13, 1993, seeking injunctive relief, annulment of the deed and title, declaration of their ownership, and monetary damages.
Petitioners filed their Answer asserting an alternative chain of title, tracing the property from its original owners (Clodualdo Sambaan and Gliceria Dacer) through an extrajudicial settlement and partition, and then a subsequent sale executed by Julian.
During trial, evidence was presented including the detailed testimony of the NBI Senior Document Examiner, who testified that the signatures on the Deed of Absolute Sale did not match the standard specimens and were therefore forged.
Other evidence included witness testimonies such as that of the caretaker and family members, which further underscored issues of authenticity regarding the document.
The RTC (Regional Trial Court) rendered a decision on August 2, 2001, declaring the Deed of Absolute Sale null and void, and awarding moral damages, attorney’s fees, and actual expenses to the respondents.
The Court of Appeals (CA) affirmed the RTC decision in totality on August 20, 2003, a ruling which was later challenged by the petitioners in a Petition for Review on Certiorari.

The disputed Deed of Absolute Sale alleged execution by Julian was scrutinized through document examination procedures carried out in accordance with standard operating protocols.
The NBI document examiner, alongside corroborative findings by the trial court and CA, concluded that the signatures of both Julian and Guillerma were not genuine.
Additional documentary evidence, including the Agreement executed on December 10, 1970 between Domingo and Patricio, was examined but ultimately found not to justify the forged act in the deed.

Whether the signatures of Julian Sambaan and Guillerma Saarenas-Sambaan on the Deed of Absolute Sale are genuine or forged.
The reliability and sufficiency of the document examiner’s testimony provided by the NBI.

Whether the forged deed validly conveyed title to the petitioners under the Torrens system.
The implications of the absence of genuine consent from the purported vendor in effectuating a valid title transfer.

Whether the doctrine of prescription bars the respondents’ action to recover ownership given the alleged implied trust created by the mortgage transaction.
The application of Article 1410 of the Civil Code regarding the non-prescription of actions to declare the inexistence of void contracts.

Whether the lower courts properly accorded probative value to the expert testimony on handwriting analysis and the documentary evidence.
Whether the trial court and the CA erred in their acceptance and interpretation of expert opinions regarding forgery.

Whether the award of moral damages, attorney’s fees, and actual expenses against petitioners was just and proper given the familial dispute and the fraud involved.