Case Digest (G.R. No. 149250)
Facts:
The case is Spouses Leon and Lolita Estacio v. Dr. Ernesto Jaranilla, G.R. No. 149250, December 08, 2003, First Division, Azcuna, J., writing for the Court. Petitioners are Spouses Leon and Lolita Estacio; respondent is Dr. Ernesto Jaranilla, who sued as heir and successor-in-interest of his mother Josefina Jaranilla. The petition challenges the Court of Appeals Decision of June 10, 1999 and Resolution of May 31, 2001, which affirmed with modification the Regional Trial Court (RTC), Branch 18, Pagadian City, Civil Case No. 3779.Sometime in 1987 Josefina Jaranilla went to live in the United States. On June 9, 1992, a parcel identified as Lot No. 202, Pls-119 (HV-81514) in Barrio Bulatoc, Pagadian City, was sold for P16,000 to Luis A. Bersales, Jr. The deed of sale was executed in the name of Josefina by Lolita F. Estacio, who claimed authorization under a Special Power of Attorney (SPA) dated July 26, 1991. The day after the conveyance, Josefina’s title was cancelled and Transfer Certificate of Title (TCT) No. T-9,455 issued to Bersales. On June 16, 1992 Bersales sold the same lot to Jorge T. Almonte, resulting in TCT No. T-9,767; subsequent proceedings led to TCT No. T-11,732 issued in the names of Almonte and his children.
Upon her return in late 1992 Josefina discovered the alleged unauthorized conveyance and, by letter dated March 24, 1993, informed the Registrar of Deeds of Zamboanga del Sur that she had not authorized any transaction and that the owner’s duplicate title remained in her possession. Nevertheless, Lolita executed another SPA dated January 4, 1993 and executed a ratificatory Deed of Sale dated April 19, 1993. Josefina died on December 19, 1994; her only son Ernesto Jaranilla, through his Attorney-in-Fact Rosalia Frias Munoz, filed a complaint for annulment of the deeds and TCTs, recovery of possession, and damages in the RTC.
Defendants Bersales and Almonte pleaded innocent purchaser in good faith and counterclaimed for damages. Lolita and her husband Leon denied wrongdoing and asserted she merely received the SPAs from Josefina’s sister. At pre-trial the parties agreed to submit the case on pleadings and documentary evidence without further testimonial proof. The RTC found the SPAs “highly questionable, spurious and self-evidently fabricated,” nullified the original sale to Bersales but upheld Almonte’s title on the ground of intervening good faith, and awarded damages. The Court ...(Subscriber-Only)
Issues:
- Did respondent prove by clear and convincing evidence that the Special Powers of Attorney and the attendant conveyances were forged?
- If forgery was not proven, was the award of damages against petitioners legal...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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