Case Summary (A.M. No. 93-10-1269-RTC)
Background of the Case
The case involves a petition for review under Rule 45 of the Rules of Court, contesting the May 27, 2002 Decision of the Court of Appeals (CA), which affirmed the dismissal of the complaint by the Regional Trial Court (RTC) of Marikina, Branch 272. The petitioner contends that the transfer of ownership of the property to respondents is based on a forged Deed of Absolute Sale, which they claim lacks legal validity.
Factual Circumstances
Petitioner Norma Domingo and her husband were the original registered owners of the lot in question. Due to financial difficulties, Norma decided to sell the property and entrusted a friend, Flor Bacani, with the responsibility of acting as her agent. Subsequent to delivering the original copy of the title to Bacani, Norma discovered that a Deed of Absolute Sale was registered, transferring the property to respondents Yolanda Robles and her children, despite the absence of any direct sale agreement between her and the respondents.
Legal Issues Raised
The primary issue raised for determination is whether the petitioner's claims of forgery regarding the Deed of Absolute Sale are substantiated and whether the respondents can be considered purchasers in good faith. Petitioner maintains that her and her husband's signatures on the Deed were forged, which invalidates the legal transfer of ownership to the respondents.
Ruling of the Court of Appeals
The CA held that the respondents were bona fide purchasers for value. The Court noted that the transaction was conducted through the petitioner’s agent, who provided the original title and was in possession of receipts. The trial court's findings indicated that there was no evidence to suggest the respondents had knowledge of any competing claims on the property. The CA ruled that the petitioner failed to prove any of her allegations regarding forgery or bad faith on the part of the respondents or their agent.
Principles of Good Faith
The Court emphasized that a notarized document carries a presumption of authenticity and valid execution until proven otherwise. Consequently, it is the burden of the petitioner to furnish clear and convincing evidence to rebut this presumption. The similarity between the signatures in the Deed of Absolute Sale and the signatures on the verification of the complaint led to the co
...continue readingCase Syllabus (A.M. No. 93-10-1269-RTC)
Case Background
- The case involves a Petition for Review under Rule 45 challenging the May 27, 2002 Decision of the Court of Appeals (CA) in CA-GR CV No. 53842.
- The CA's decision affirmed the dismissal of the complaint by the Regional Trial Court (RTC), Branch 272 of Marikina.
- The RTC's decision stated that the complaint was dismissed based on the facts presented.
Factual Context
- Ownership History: Norma B. Domingo and her husband, Valentino Domingo, were the registered owners of Lot 19, Block 1, subdivision plan (LRC) Psd-15706 located at Cristina Subdivision, Concepcion, Marikina, covered by Transfer Certificate of Title No. 53412.
- Agent Involvement: Norma Domingo, having ceased construction on the property due to financial issues, entrusted her friend Flor Bacani as her agent to sell the property. She handed over the original title and other relevant documents to Bacani.
- Allegations of Fraud: Upon discovering that the property was being developed by the respondents, Norma Domingo found that a Deed of Absolute Sale dated May 9, 1991, had been executed without her consent and that her signature was purportedly forged.
Respondents' Claims
- Good Faith Purchase: The respondents, Yolanda Robles and her minor children, claimed they were good faith purchasers. They stated that they were introduced to the alleged sellers by Bacani and that they paid the full purchas