G.R. No. 237465 - Spouses Coronel vs. Quesada

In September 2011, the Spouses Coronel filed a complaint for annulment of deeds, cancellation of TCT No. 335024, recovery of possession, reconveyance with preliminary injunction, and damages against Corazon Solis-Quesada (Quesada).
They alleged ownership over Lot 9747-C in San Vicente, Sta. Ignacia, Tarlac City, originally covered by TCT No. 156304 and measuring 1,379 square meters.

During the early 1980s, Asuncion’s aunt, Catalina Hernando, was permitted to construct a house on a portion of the property and act as caretaker while the spouses attended business in Angeles City, Pampanga.
The spouses entrusted Catalina with the title and other documents related to the property for tax and other purposes.
Allegedly, as Catalina became ill, her granddaughter Mina M. Delos Reyes purportedly obtained TCT No. 156304 and mortgaged the property without the spouses’ knowledge.

In 2005, the spouses discovered that a Deed of Donation—allegedly showing that they donated the property to Mina Delos Reyes—had been filed, leading to the cancellation of TCT No. 156304 and the issuance of TCT No. 292249 in Delos Reyes’ name.
Subsequently, Delos Reyes and her husband Rodrigo A. Rodrigo executed a Deed of Absolute Sale on June 16, 2000, which resulted in TCT No. 335024 being issued in Quesada’s name.
The spouses contended that they neither executed the Deed of Donation nor the Deed of Absolute Sale, claiming that both documents were falsified and forged.
They further alleged collusion between Delos Reyes and Quesada, asserting that Quesada, as a close associate (and live-in partner of a family member of Delos Reyes), was not an innocent purchaser.

After the spouses presented their evidence, Quesada filed a Motion to Dismiss on a Demurrer to Evidence, arguing that the evidence was insufficient to support the cause of action.
On April 28, 2014, the RTC of Camiling, Tarlac, granted the motion to dismiss, basing its decision on two grounds: (a) the action for reconveyance was time-barred (more than 10 years had passed since the donation), and (b) there was insufficient evidence of actual and continuous possession.
The Court of Appeals (CA), in its July 11, 2017 Decision and January 22, 2018 Resolution, affirmed the RTC’s dismissal, finding that the spouses failed to prove the forgery issues and did not establish the requisites for reconveyance.

The spouses relied heavily on Asuncion’s Judicial Affidavit, in which she asserted that the signatures on the Deed of Donation and Deed of Absolute Sale did not match their genuine signatures.
They introduced documents and testimonies suggesting discrepancies, such as the significant period differences between signature specimens and the questioned signatures, and noted that Rodrigo’s alleged signature on the deed of sale did not align with his other signature samples.
No corroborative testimony from other witnesses or an expert opinion was presented to conclusively establish the alleged forgery.

The spouses argued that the action for reconveyance should not prescribe because they claimed continuous and actual possession of the property.
However, evidence, including the testimony of a tenant who knew of a different owner before his occupancy, cast doubt on the claim of uninterrupted possession.
The courts observed that the complaint was filed more than 10 years after the disputed donation and that mere denial was not enough to overcome the presumption of regularity of notarized documents.

The spouses argued that non-compliance with statutory formalities (such as the requirements under Act No. 496 for notarization and the presence of two witnesses) further vitiated the disputed deeds.
They contended that the alleged forgery in their signatures, combined with substantive evidence of collusion between Delos Reyes and Quesada, should entitle them to reconveyance of the land.
Despite these allegations, no clear, positive, and convincing evidence was provided to support the claims, and many issues were raised for the first time only on appeal or in the motion for reconsideration.

Whether the petition allows a review of the factual findings of the RTC and CA regarding issues such as forgery, possession, and prescription.

Whether the spouses presented clear and convincing evidence establishing that the deeds (the Deed of Donation and the Deed of Absolute Sale) were forged.
Whether such evidence was sufficient to warrant the reconveyance of the subject property.

Whether the differences between the disputed signatures and recognized samples were adequately examined.
Whether the absence of expert testimony or proper comparative analysis undermined their allegation of forgery.

Whether Quesada acquired the title in good faith and for value despite the alleged fraudulent documents.
Whether her relationship with Delos Reyes and the surrounding facts precluded her from being an innocent purchaser.

Whether the action for reconveyance has already prescribed by virtue of being filed over 10 years from the issuance of the contested title.
Whether the demonstration (or lack thereof) of continuous possession affects the prescriptive period.