Case Summary (G.R. No. 191936)
Procedural History and Property Title Issue
Following Silvestra’s death in 2002, the petitioner purportedly acquired Silvestra’s portion of the property through a Deed of Sale dated January 18, 2005, leading to the cancellation of the original title (TCT No. 183088) and issuance of a new title (TCT No. 221466) under the petitioner's sole name. The respondents later challenged this, alleging forgery of the Deed of Sale and fraudulent cancellation of the original title.
Criminal Complaint and Civil Action
Respondents filed a criminal complaint against the petitioner for falsification of public documents, which was eventually dismissed. Subsequently, they instituted a civil action for annulment of the Deed of Sale and cancellation of the new title with damages. The petitioner countered that respondents lacked legal capacity to sue as they were illegitimate children, purportedly barred from inheriting under Article 992 of the Civil Code.
Regional Trial Court’s Ruling
The RTC found the Deed of Sale forged, as Silvestra had died three years before its execution. It declared the sale null and void, ordered cancellation of the new title and reinstatement of the original title, and awarded damages to the respondents. The RTC also ruled that respondents had the legal personality to sue, holding that their filiation to Anastacio, Sr. was legitimate based on marriage evidence and birth certificates.
Court of Appeals Decision
The CA affirmed the RTC decision with modification to reduce damages. It held that the cancellation and reissuance of title had been obtained through forgery. The CA similarly upheld the respondents’ legitimacy and legal capacity to sue, emphasizing the presumption in favor of marriage and legitimacy supported by a marriage contract and canonical certificate, as well as the respondents’ birth certificates indicating Filiations.
Petitioner’s Arguments on Legitimacy
The petitioner challenged the sufficiency of marital proof between Anastacio, Sr. and Fidela, asserting that the marriage contract was inadmissible secondary evidence lacking proper authentication, and the canonical certificate was inadequate proof of marriage under the Family Code. She also argued the birth certificates failed to conclusively prove legitimacy, claiming the absence of the father’s signature invalidated them as evidence of paternity.
Respondents’ Defense and Legal Capacity
Respondents maintained that legitimacy presumptions are strong and can only be questioned in a direct action by qualified parties. They emphasized that the certificates of live birth are public documents entitled to prima facie evidentiary weight. The canonical marriage certificate and birth certificates collectively substantiated their legitimate filiation to Anastacio, Sr.
Supreme Court’s Evidentiary Analysis on Proof of Marriage
The Court acknowledged that while the original marriage contract was not produced, the secondary evidence submitted complied with the requirements under the Rules on Evidence by proving the existence and lawful execution of the original document without bad faith. The canonical certificate, although a private writing, was admissible as corroborative evidence but required authentication which was absent. However, proof of marriage could also be established by other relevant evidence such as cohabitation, birth certificates of offspring, and public acknowledgment.
Presumption of Marriage and Legitimacy
The Court noted the long-standing jurisprudential presumption that persons living as husband and wife are presumed legally married absent evidence to the contrary. The Respondents’ birth certificates reflected that their parents were married, and Fidela's signature as informant validated the registration of birth and parentage under the law—birth certificates being public documents and prima facie evidence of facts therein.
Legitimacy under Section 5 of Act No. 3753
The Court rejected the petitioner’s contention that the fathers’ signature is necessary in birth certificates to establish legitimacy, citing Section 5 of Act No. 3753, which
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Facts of the Case
- Virginia D. Calimag (petitioner) and Silvestra N. Macapaz (Silvestra) co-owned a property located at No. 1273 Bo. Visaya Street, Barangay Guadalupe Nuevo, Makati City, with an area of 299 square meters.
- Title to the property was registered under Transfer Certificate of Title (TCT) No. 183088, issued in the names of petitioner and Silvestra.
- An adverse claim was annotated by Fidela O. Poblete Vda. de Macapaz (Fidela) over a 49.5 square meter portion of the property.
- Silvestra died on November 11, 2002, without leaving issue.
- On January 18, 2005, a Deed of Sale purportedly executed by Silvestra sold her 99-square meter portion to petitioner for ₱300,000.00 and led to the cancellation of TCT No. 183088 and issuance of TCT No. 221466 in petitioner’s name.
- An affidavit dated July 12, 2005, allegedly signed by both petitioner and Silvestra, claimed the adverse claim by Fidela was legally ineffective due to lack of proper signing.
- Fidela died on September 16, 2005.
- Respondents, identified as heirs of Silvestra and children of Anastacio Sr. and Fidela, filed an annulment suit against the petitioner for annulment of deed of sale and cancellation of TCT No. 221466.
- Petitioner contended respondents have no legal capacity to sue, asserting they were illegitimate children barred from inheritance under Article 992 of the Civil Code.
- RTC Makati ruled in favor of respondents, declaring the deed of sale void due to forgery since Silvestra was deceased before its execution, ordering cancellation of TCT No. 221466 and reinstatement of original title, and awarding damages.
- RTC also recognized respondents’ legitimacy and capacity to sue based on presented certificates of birth, marriage, and facts of cohabitation.
Issues Presented
- Whether the deed of sale executed by Silvestra in 2005 is null and void.
- Whether the respondents have the legal capacity to file an annulment and cancellation suit as heirs of Silvestra.
- Whether the respondents are legitimate children of Anastacio Sr. and Fidela, thus legally entitled to inherit from Silvestra’s estate.
- Admissibility and sufficiency of evidence proving marriage between Anastacio Sr. and Fidela, and the filiation of respondents.
Ruling of the Regional Trial Court (RTC)
- The deed of sale dated January 18, 2005 was found to be a forgery, null, and void because Silvestra died in 2002, making it impossible she executed the deed.
- The cancellation of TCT No. 183088 and issuance of TCT No. 221466 in petitioner’s name were based on fraudulent documents.
- Ordered cancellation of TCT No. 221466 and reinstatement of TCT No. 183088 inclusive of liens and Fidela’s adverse claim.
- Awarded moral and exemplary damages to respondents and attorney’s fees.
- Recognized respondents as legitimate heirs based on birth certificates and marriage proof.
- Dismissed petitioner’s counterclaim for lack of merit.
- Held that the respondents’ status as legitimate heirs gave them legal personality to prosecute the suit.
Ruling of the Court of Appeals (CA)
- Affirmed RTC decision with a modification reducing damages awarded from ₱100,000 to ₱50,000 for moral and exemplary damages.
- Sustained RTC’s finding of forgery and fraud in obtaining cancellation of original title.
- Upheld legitimacy of respondents based on evidence of marriage of Anastacio Sr. and Fidela:
- Marriage certificat