G.R. No. 142309 - Spouses Dela Rama vs. Papa

Juan and Eugenia dela Rama were registered owners of a parcel of land in Calamba, Laguna, covered by Transfer Certificate of Title (TCT) No. 91166, acquired for ₱96,000 by a notarized Absolute Deed of Sale dated July 10, 1980, from Canlubang Sugar Estate (CSE). Eugenia affixed her signature as proof of marital consent.
Juan dela Rama became a US resident in 1984 and gained American citizenship by 1989.

In 1992, petitioners were informed by the assessor’s office that their title had been cancelled, and a new title, TCT No. 102128, was issued in favor of respondents Oscar and Ameurfina Papa.
Oscar Papa was Assistant Vice-President and Head of Marketing of Laguna Estate Development Corporation (LEDC), a marketing arm of CSE, until July 31, 1985.

The property was transferred to respondents and retitled under TCT No. 102128 based on a notarized Deed of Absolute Sale dated March 29, 1985, identifying petitioners as vendors and respondents as vendees.
The deed bore signatures of petitioners, respondents, two unidentified witnesses, and the notarial seal and signature of Atty. William Gumtang. The new title was issued to respondents on June 21, 1985.
Petitioners alleged their signatures on the 1985 deed were forged and filed a complaint for cancellation of title obtained under a forged deed. They sought nullity of the 1985 deed and restoration of their title.

Respondents claimed the deed was duly executed, that laches barred the complaint, and that they were buyers in good faith and for value. They asserted they reasonably believed the seller was authorized due to possession of the owner’s duplicate TCT.
Stipulated facts included: original ownership by Juan dela Rama, cancellation of TCT No. 91166, issuance of TCT No. 102128 to respondents, Oscar Papa’s employment with LEDC, and LEDC’s role as developer and marketer of the subdivision.

Petitioners denied signing the 1985 deed or any document transferring their rights, and denied having met Oscar Papa before testifying in court.
Oscar Papa admitted signing the deed but did not see petitioners sign; he did not recall signing it before the notary and admitted buyer typically signed first in real estate deals. He also admitted not recalling who offered the property or to whom the payment was made.

On June 26, 1986, the RTC annulled the 1985 deed of sale, cancelled respondents’ title, and reinstated petitioners’ title.
RTC found preponderant evidence that petitioners’ signatures were forged, corroborated by Papa’s admission of not seeing petitioners sign.
It rejected respondents’ claim regarding standard practice and good faith, noting lack of payment of taxes and absence of possession by respondents.
The RTC held laches and estoppel did not bar petitioners’ action, citing pertinent laws prohibiting acquisition of land title by prescription or adverse possession.

On September 7, 1999, the CA reversed the RTC, upholding the validity of the deed.
The CA held petitioners failed to prove forgery with convincing evidence, citing only Juan dela Rama’s oral, self-serving testimony.
The CA criticized RTC’s failure to apply Section 22, Rule 132, requiring proof of handwriting by a witness with knowledge.
The CA noted that neither petitioner was confronted with the questioned signatures nor declared unequivocally that these were forged.

Petitioners emphasize admissions by Oscar Papa undermining the deed’s validity.
The issue focuses on whether the deed’s signatures were forged, and whether the deed was properly notarized, affecting presumptions of authenticity.

Whether the signatures of the petitioners on the 1985 Deed of Absolute Sale were forged.
Whether the deed of sale was properly notarized and entitled to the presumption of regularity and authenticity as a public document.
Whether respondents can be considered purchasers in good faith despite disputed execution of the deed.
What is the applicable standard of proof to be applied in proving forgery and genuineness of signatures on a private document.