Case Digest (G.R. No. 193007)
Case Digest (G.R. No. 193007)
Facts:
Spouses Romulo and Sally Eduarte v. The Honorable Court of Appeals and Pedro Calapine (substituted by Alexander Calapine and Artemis Calapine), G.R. No. 105944, February 09, 1996, Supreme Court Third Division, Francisco, J., writing for the Court. Narvasa, C.J. (Chairman), Davide, Jr., Melo and Panganiban, JJ., concur.The original owner, Pedro Calapine, held OCT No. P-2129 for a 12,199 sqm parcel in San Cristobal, San Pablo City. On April 26, 1984 he executed a deed of donation (a "pagbibigay-pala") conveying one-half of the parcel to his niece, Helen S. Doria. On July 26, 1984 a second deed, similarly captioned, was produced purporting to donate the entire parcel to Helen; based on that instrument the OCT was cancelled and TCT No. T-23205 was issued in Helen’s name.
On February 26, 1986 Helen donated 157 sqm of the parcel to Calauan Christian Reformed Church, Inc., producing new TCTs reflecting that transfer and the residue in her name. On March 25, 1988 Helen sold the remaining portion (less a 700-sqm area) to spouses Romulo and Sally Eduarte, and TCT No. T-27434 was subsequently issued in the Eduartes’ names.
Claiming that his signature on the July 26, 1984 deed was forged and that Helen had been unworthy (ingratitude), Pedro sued Helen, the Church and the Eduartes to revoke the April donation, annul the July donation and the later deeds of donation and sale, and cancel the TCTs. The Church reconveyed its portion and was dismissed; Helen and local officials did not answer. After Pedro’s death his nephews Alexander and Artemis Calapine were substituted as plaintiffs.
The Regional Trial Court (RTC), Branch 30, San Pablo City, after trial, found for plaintiff: it revoked the April 26, 1984 donation, annulled the July 26, 1984 donation, annulled the March 25, 1988 sale and TCT No. T-27434, and ordered issuance of a new title in favor of the substitute-plaintiffs; it also awarded attorneys’ fees and, on the Eduartes’ cross-claim, judgment against Helen for P110,000 with interest. Only the Eduartes appealed.
The Court of Appeals (CA) in CA-G.R. CV No. 29175 (Apr. 22, 1992) affirmed the RTC: it credited the NBI handwriting expert that Pedro’s signature on the July deed was forged, held that falsification constituted ingratitude warranting revocation under Article 765 of the Civil Code, and found the Eduartes were not purchasers in good faith because circumstances (occupants, houses, trees) should have aroused suspicion. The Eduartes filed a petition for certiorari to the Supreme Court challenging the CA’s findings.
Issues:
- Was the July 26, 1984 deed of donation in which Pedro Calapine’s signature was questioned conclusively shown to be a forgery such that the courts below properly credited the handwriting expert who found it forged?
- Does the falsification by the donee constitute "ingratitude" within the meaning of Article 765 of the Civil Code, thereby justifying revocation of the donation?
- Were petitioners spouses Romulo and Sally Eduarte purchasers in good faith such that the annulment of their deed of sale and cancellation of their TCT should be set aside?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)