G.R. No. 139230 - People vs. Daniela

Case Summary (G.R. No. 139230)

Relevant Dates and Applicable Law

The dispute emerged in 2001 with the Deed of Absolute Sale dated July 16, 2001. Following court proceedings, the final Supreme Court decision was rendered on August 23, 2017. As the decision postdates 1990, the 1987 Philippine Constitution governs the legal framework applied, particularly Section 7, Article XII, concerning restrictions on alien ownership of land.

Facts and Procedural History

Peter Donton discovered respondents' possession of the property in 2001 and alleged that the sale was fraudulent, particularly challenging the authenticity of the signature on the Deed of Absolute Sale. He claimed he never signed the deed, was not physically present in the Philippines on July 16, 2001, and that the sale was facilitated through collusion with local Registry of Deeds employees. Petitioner sought annulment of the title and reconveyance of the property with damages.

Respondents contended a lawful basis for ownership, pointing to prior agreements: an Occupancy Agreement (1995), a secured P3,000,000.00 loan mortgage, and a Special Power of Attorney (SPA) granting authority to Stier to sell the property. They contended Donton's failure to pay debts led to the sale. Respondents also counterclaimed for damages.

The trial court dismissed the complaint due to lack of sufficient evidence, emphasizing the presumption of regularity accorded public documents like the Deed of Absolute Sale and TCT. Expert witness Perez's forensic handwriting analysis was deemed self-serving due to unverified sources for standard signatures. The court also found petitioners failed to conclusively establish key allegations, including Stier's citizenship and marital status, and the incapacity of Maggay to acquire property.

Court of Appeals' Findings

The Court of Appeals affirmed the dismissal, upholding the presumption of validity of notarized documents and requiring clear and convincing evidence to overturn such presumption. They observed the passport entry and exit stamps produced by petitioners did not conclusively prove physical absence from the Philippines on the deed’s date. The appellate court accorded little weight to the expert’s testimony due to deficiencies in verifying sources of specimen signatures. It likewise upheld the lower court’s findings regarding the insufficiency of proof on Stier's citizenship and other allegations.

Issue Presented to the Supreme Court

Whether the Court of Appeals erred in ruling that petitioners failed to discharge the burden of proof necessary to annul the title and order reconveyance with damages.

Supreme Court's Analysis on Burden of Proof and Evidence

The Court reiterated the general rule that only questions of law may be reviewed on certiorari but acknowledged exceptions when findings of fact are unsupported or contradicted by evidence. The burden to prove forgery lies with the party alleging it, requiring clear, positive, and convincing evidence, typically demonstrated by comparison with genuine signatures.

The Supreme Court affirmed the necessity that evidence of handwriting must be authenticated, citing Section 22, Rule 132 of the Revised Rules of Court, which governs the proof of genuineness of handwriting. The Court referred to jurisprudence emphasizing that dissimilarities in handwriting alone do not conclusively establish forgery due to multiple factors affecting writing. Expert reports are advisory, and the court should independently evaluate signature authenticity.

In this case, the expert’s examination was discounted due to unverified sources of specimen signatures, impairing probative value. Similarly, passport stamps presented did not exclude the possibility of Donton’s presence in the Philippines on July 16, 2001, especially as he admitted returning to the Philippines in the last week of July 2001, undermining his credibility.

Citizenship and Alien Ownership Issue

Contrary to previous court rulings, the Supreme Court found sufficient proof that Duane Stier is an American citizen, based on admissions in the pleadings and an affidavit executed by Stier himself. This admission carries binding effect as an admission against interest.

Consequently, the transfer of real property to Stier, a foreign national, violates Section 7, Article XII of the 1987 Constitution, which prohibits aliens from owning private lands in the Philippines, rendering the sale void ab initio as to him. The SC cited jurisprudence establishing that contracts violating constitutional provisions are null and void and confer no rights or obligations.

As such, Stier cannot recover any payment m

Case Syllabus (G.R. No. 139230)

Background and Parties Involved

The petitioners are the heirs of the late Peter Donton, represented legally by Felipe G. Capulong.
The respondents are Duane Stier and Emily Maggay.
The subject matter concerns a parcel of land with improvements located at No. 33, Don Jose Street, Murphy, Cubao, Quezon City, measuring approximately 553.60 square meters.
Originally, the land was titled under Peter Donton via Transfer Certificate of Title (TCT) No. N-137480.
The title was later transferred to Duane Stier and Emily Maggay, evidenced by TCT No. N-225996.

Facts and Initial Claims

In June 2001, while Donton was in the United States, respondents took possession and control of the property and managed a business operating thereon.
Donton’s lawyers demanded that respondents vacate and cease business operations, but respondents did not comply.
Donton returned to the Philippines and discovered, through alleged fraudulent means, that the property ownership was transferred to respondents.
TCT No. N-137480 was canceled, and a new title under TCT No. N-225996 was issued to respondents.
The complaint alleged that the Deed of Absolute Sale dated July 16, 2001, was based on a forged signature of the late Donton.
Donton denied executing the deed, supporting that he was in the United States from June 27 to August 30, 2001.
The complaint also alleged complicity of respondents with Registry of Deeds employees and claimed that Duane Stier, being a non-resident alien American citizen, was legally disqualified from acquiring real property in the Philippines.
Relief sought included annulment of TCT No. N-225996, reconveyance to the original owner, and damages.

Respondents’ Defense and Counterclaim

Respondents claimed a lawful transaction supported by:
- An Occupancy Agreement dated September 11, 1995, acknowledging Stier’s residence from January 5, 1995.
- A loan to Donton amounting to P3,000,000.00 secured by a mortgage on the subject property.
- A Special Power of Attorney (SPA) executed by Donton in favor of Stier authorizing sale, mortgage, or lease of the property.
Due to failure to pay the loan, respondents executed a unilateral contract of sale dated June 25, 2001.
Eventually, a Deed of Absolute Sale was executed on July 16, 2001.
Respondents argued Donton was aware of the sale and prayed for damages as counterclaims.

Trial Evidence and Expert Testimony

Petitioners presented Rosario C. Perez, Document Examiner II of the PNP Crime Laboratory, who found significant divergences between alleged forged signature and standard signatures of Donton.
Perez testified that the questioned signatures were not written by the same person.
Respondents waived their right to present evidence.
Upon Donton’s death, the substitution of his heirs as plaintiffs was allowed.

Regional Trial Court (RTC) Ruling

The RTC dismissed the complaint due to insufficient evidence.
Held the Deed of Absolute Sale as a public and notarized document, presuming its regularity.
Found Perez’s forensic e