Case Summary (G.R. No. 158015)
Background of the Case
Cesar Morelos sold the property to Laura Bautista during his lifetime, resulting in the issuance of a new Transfer Certificate of Title in her name. However, after Cesar's death, Fernando Morelos filed a complaint seeking to nullify the sale and title based on alleged forgery of the signature on the deed. The Regional Trial Court initially ruled in favor of Laura Bautista, validating the deed, but this decision was appealed to the Court of Appeals which reversed the ruling.
Court of Appeals Ruling
The Court of Appeals issued a decision declaring the Deed of Absolute Sale null and void. It based its ruling on testimonies from expert witnesses, who claimed that Cesar Morelos's signature was forged. The appellate court mandated the cancellation of Laura Bautista's title to the property and directed the issuance of a new title in the name of Cesar Morelos's estate.
Issues Raised
The critical issues raised in the petition for review included: (1) whether expert witness testimonies are a sufficient basis to nullify a notarized deed, (2) whether the Deed of Absolute Sale is valid, and (3) whether Fernando Morelos has the legal standing to seek annulment of the deed.
Analysis of Expert Testimony
The petitioner contended that the Deed was valid, emphasizing the testimony of Carmelita Marcelino, the witness to the signing. In contrast, Fernando Morelos argued that the signature was forged, presenting the opinion of Francisco Cruz, an expert from the PC-INP Crime Laboratory. The court evaluated the weight of direct evidence from witnesses versus circumstantial evidence provided by experts, concluding that mere expert testimony could not sufficiently override the direct testimony of a witness present during the transaction.
Legal Standards on Forgery
Philippine law stipulates that a duly notarized contract is presumed authentic and regularly executed unless credible evidence proves otherwise. The burden lies with the party alleging forgery to provide clear and convincing proof, which was found lacking in this case. The court established that the presumption of validity and regularity of the notarized document should prevail unless convincingly rebutted.
Rebuttal of Claims of Forgery
The court emphasized the necessity of not relying solely on the assessments of handwriting
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Case Background
- The case is a Petition for Review on Certiorari under Rule 45 of the 1997 Rules on Civil Procedure.
- The petitioners, Laura and Eriberto Bautista, appeal a decision from the Court of Appeals (CA-G.R. CV No. 45549) that reversed the judgment of the Regional Trial Court (RTC) of Manila, Branch VII in Civil Case No. 83-17900.
- The RTC had originally ruled in favor of the petitioners, affirming the validity of a Deed of Absolute Sale dated April 5, 1982, executed between the late Cesar Morelos and Laura Bautista.
- The parcel of land in dispute is located along Maceda Street, Sampaloc, Manila, covering approximately 105 square meters.
Parties Involved
- Petitioners: Laura and Eriberto Bautista.
- Respondent: Fernando Morelos, claiming to be the illegitimate child of Cesar Morelos with Angelina Lim-Gue.
Key Facts
- The land was previously owned by Cesar Morelos, uncle to Laura Bautista.
- Cesar Morelos, who was childless, sold the land to Laura Bautista before his death on April 15, 1982.
- A Deed of Absolute Sale was notarized by Luis M. de Guzman, leading to the issuance of Transfer Certificate of Title No. 254843 in Laura's name.
- Fernando Morelos filed a complaint for nullity of the sale and title with damages, asserting that the sale was invalid due to forged signatures.
Court Proceedings
- At trial, Fernando presented expert witnesses who claimed