G.R. No. 246989 - Heirs of Lagon vs. Ultramax Healthcare Supplies, Inc.

Case Summary (G.R. No. 246989)

Factual Background

The parties disputed ownership of two parcels in Marbel, Koronadal City, originally covered by Transfer Certificate of Title Nos. T-72558 and T-72564 in the names of spouses Jose and Nenita Lagon. The Lagon Spouses discovered that the Registry of Deeds had cancelled those titles and replaced them with TCT Nos. T-141372 and T-131373 issued in the name of Ultramax Healthcare Supplies, Inc. The Lagon Spouses denied any sale and averred that the cancellation and transfers resulted from a falsified Deed of Absolute Sale purportedly executed in their favor.

Trial Court Proceedings

The Lagon Spouses filed a complaint for annulment of title on September 29, 2011. During trial, the heirs presented a forensic handwriting examination that found the signatures on the questioned Deed of Absolute Sale to be falsified. Respondents later sought to introduce a Deed of Mortgage dated December 2009. The trial court admitted a Supplemental Judicial Affidavit that attached the Deed of Mortgage and, citing substantial justice and equity, allowed the Deed of Mortgage to be examined by an NBI handwriting expert for purposes of comparison.

The Parties' Contentions at Trial

Petitioners contended that the Deed of Mortgage was never pleaded and that admitting it at trial violated the Judicial Affidavit Rule and the pre-trial identifications. Petitioners argued further that the Deed of Mortgage was immaterial to the Complaint that challenged only the Deed of Absolute Sale. Respondents maintained that the Deed of Mortgage constituted defensive evidence aimed at rebutting the forensic findings and that its signatures were relevant for comparison to determine the authenticity of the signatures on the Deed of Absolute Sale.

Procedural Challenge in the Court of Appeals

The heirs filed a petition for certiorari with the Court of Appeals, alleging grave abuse of discretion by the trial court in ordering the NBI examination of a document never pleaded and allegedly already ruled inadmissible. The Court of Appeals dismissed the petition, holding that the trial court sought only to determine the authenticity of signatures and that it had not ruled on the admissibility of the Deed of Mortgage per se. The CA further recognized the trial court's authority to admit or reject evidence determinative of the case.

Issue Presented to the Supreme Court

The principal issue was whether the Court of Appeals erred in finding that the Regional Trial Court did not commit grave abuse of discretion in granting respondents’ motion to have the Deed of Mortgage examined by a handwriting expert, despite the document not having been identified and pre-marked during pre-trial.

Supreme Court Ruling (Disposition)

The Supreme Court denied the petition for review and affirmed the January 31, 2019 Decision and May 8, 2019 Resolution of the Court of Appeals. The Supreme Court held that the Regional Trial Court did not act with grave abuse of discretion in admitting the Supplemental Judicial Affidavit and directing the NBI handwriting examination of the Deed of Mortgage.

Legal Basis and Reasoning

The Court determined that procedural rules, including the Judicial Affidavit Rule, are designed to facilitate trial and promote substantial justice rather than to produce outcomes based on mere technicalities. The Court interpreted A.M. No. 03-1-09-SC and section 2 of the Judicial Affidavit Rule to permit the trial court, for good cause shown, to admit documentary evidence not previously identified and pre-marked during pre-trial. The Court relied on Cruz v. People, which recognized that the admission of unmarked evidence is not absolutely prohibited and defined "good cause" as a substantial reason that affords a legal excuse. The Court found that the need to introduce the Deed of Mortgage arose only after petitioners presented forensic results impeaching the signatures on the Deed of Absolute Sale, thereby justifying respondents' effort to obtain comparable handwriting for rebuttal. The Court invoked Rule 128, Rules of Court, sec. 4 on relevancy to conclude that signatures on the Deed of Mortgage were reasonably probative of the main issue, namely, the authenticity of the signatures on the Deed of Absolute Sale. The Court also obse

Case Syllabus (G.R. No. 246989)

Parties and Posture

HEIRS OF JOSE V. LAGON, NAMELY: MARIA JOCELYN LAGON-RODRIGUEZ, ARMANDO L. LAGON, JONALD JOSE L. LAGON, JOSELITO L. LAGON, LEILANIE L. LAGON, JOSE L. LAGON, JR., MARY EMILIE LAGON-SANCHEZ, STEFANIE GRACE L. LAGON, RYAN NEIL L. LAGON, NENITA L. LAGON, JR., AND NENITA L. LAGON were the petitioners before the Supreme Court challenging the admission of evidence.
ULTRAMAX HEALTHCARE SUPPLIES, INC., MARGIE K. HUAN, MELODIE ANNE KO HUAN, MAEL ALLISON KO HUAN, GIANNE CARLO KO HUAN, ROSANA M. NAVARRO, AND THE REGISTER OF DEEDS FOR THE PROVINCE OF SOUTH COTOBATO were the respondents in the original annulment action and in the collateral proceedings.
The petition sought review of the Court of Appeals' January 31, 2019 Decision and May 8, 2019 Resolution in CA-G.R. SP No. 08653-MIN affirming the Regional Trial Court's admission of a late evidence item for expert examination.
The petition presented the question whether the Court of Appeals erred in finding no grave abuse of discretion in the trial court's allowance to examine a previously unmarked Deed of Mortgage by a handwriting expert.

Key Facts

Spouses Jose and Nenita Lagon were registered owners of lands covered by TCT Nos. T-72558 and T-72564 which were later cancelled and replaced by TCT Nos. T-141372 and T-131373 in favor of Ultramax.
The petitioners alleged that the transfer arose from a falsified Deed of Absolute Sale and denied any sale of the properties.
Ultramax alleged a 2009 loan of P2.3 million by Margie Huan secured by the two properties and later a cession of the properties to Huan with Ultramax as transferee.
A deposition by a facilitator named Al Barrometro stated that a Deed of Absolute Sale purportedly executed by the Lagon Spouses and notarized by Atty. Damaso Cordero was presented to the Registry of Deeds.
A forensic handwriting examination requested by petitioners showed the signatures on the Deed of Absolute Sale to be falsified.
Ultramax thereafter sought admission of, and later submitted, a separate Deed of Mortgage dated December 2009 which was not identified or pre-marked at pre-trial.

Procedural History

Petitioners filed an annulment complaint on September 29, 2011 contesting the new titles.
Trial commenced after substitution of heirs following Jose Lagon's death and pre-trial proceedings were held.
Petitioners tendered evidence, rested, and had a forensic report showing forgery of the Deed of Absolute Sale admitted in evidence.
Ultramax served Requests for Admission for the Deed of Mortgage and later filed a Supplemental Judicial Affidavit introducing the Deed of Mortgage during trial.
The Regional Trial Court admitted the Supplemental Judicial Affidavit and allowed the Deed of Mortgage to be examined by an NBI handwriting expert.
Petitioners filed a petition for certiorari in the Court of Appeals alleging grave abuse; the Court of Appeals dismissed the petition.
Petitioners filed a Petition for Review on Certiorari before the Supreme Court contesting the appellate affirmance.

Issues Presented

Whether the trial court gravely abused its discretion in allowing the post–pre-trial Deed of Mortgage to be examined by a handwriting expert.
Whether the Deed of Mortgage was irrelevant or barred from introduction because it was not alleged in respondents' pleadings nor pre-marked at pre-trial.
Whether procedural rules required strict exclusion of unmarked evidence absent a showing of rigid compliance.

Contentions of Parties

Petitioners contended that the Deed of Mortgage was never mentioned in respondents' Answer or other pleadings and that the trial court had already ruled it inadmiss