Case Summary (G.R. No. 256868)
Background of the Dispute
Cipriano acquired Lot No. 5053-H in 1940 and took possession, cultivated the land, and paid taxes diligently. In 1949, Dionisio purchased an adjacent parcel of land but encroached on a small section of Cipriano's lot. A confrontation ensued in 1952, where Cipriano refused Dionisio's offer to buy the encroached portion. Cipriano later allowed Dionisio to build a house on that portion temporarily, during which no legal action was taken against him until Cipriano's death in May 1982. After Cipriano's death, his son Hermogenes continued to cultivate the lot. The controversy arose in 1997 when petitioners found out that Tax Declaration No. 07764 for Lot No. 5053-H was canceled and replaced with Tax Declaration No. 23959 in Dionisio's name, based on the disputed Deed of Absolute Sale.
Procedural History
The petitioners filed a Complaint in July 1997 against the respondents for quieting of title, annulment of the deed of sale, cancellation of the new tax declaration, recovery of possession, and damages, asserting that the deed was a forgery. The respondents, on the other hand, claimed the deed was genuine and sought damages as a counterclaim. The Regional Trial Court (RTC) annulled the deed, citing evidence including the document examiner's opinion that Cipriano’s signature was forged and the circumstances surrounding the acquisition of the property. The RTC also ordered the respondents to vacate the property.
Court of Appeals Ruling
The Court of Appeals (CA), however, reversed the RTC’s decision, stating that the petitioners failed to prove the forgery allegation adequately. The CA observed that notarized documents enjoy a presumption of authenticity and it deemed that the document examiner did not ascertain the forgery with certainty. Furthermore, it noted that respondents had established possession of the lot since their house was built on it.
Issues Raised
The petitioners raised several issues in their Petition for Review on Certiorari, highlighting alleged errors by the CA, including the failure to overturn the presumption of regularity of the deed, the insufficient findings on forgery, and the issue of possession of Lot No. 5053-H.
Supreme Court's Analysis
The Supreme Court determined that the findings of fact from the RTC should be upheld given the discrepancies in the CA's conclusions. It highlighted the substantial evidence presented by the petitioners demonstrating the forgery of the deed. The document examiner's report was deemed credible, as it indicated significant differences betwe
...continue readingCase Syllabus (G.R. No. 256868)
Case Overview
- Court: Supreme Court of the Philippines
- Division: First Division
- G.R. No.: 175874
- Date: December 11, 2013
- Parties:
- Petitioners: Heirs of Cipriano Trazona (Francisca T. Matbagon, Natividad T. Abadiano, Carlito C. Trazona, and others)
- Respondents: Heirs of Dionisio Caada (Rosita C. Gersalina, Conception C. Geonzon, Daniel Caada, Gorgonio Caada, others)
Background of the Case
- The case revolves around a dispute regarding Lot No. 5053-H located in Minglanilla, Cebu, originally owned by Cipriano Trazona.
- Cipriano purchased the land from the government in 1940 and cultivated it while paying taxes diligently.
- Dionisio Caada, who purchased an adjacent parcel in 1949, encroached on a small portion of Lot No. 5053-H.
- A confrontation occurred in 1952, and although Dionisio sought to buy the encroached land, Cipriano refused.
- In 1956, Cipriano allowed Dionisio to build a house on the encroached portion temporarily.
- No legal action was taken against Dionisio during Cipriano's lifetime.
Events Leading to the Controversy
- After Cipriano's death on May 18, 1982, his son Hermogenes took over the cultivation of the land.
- In 1992, Dionisio also passed away.
- In 1997, petitioners discovered that Tax Declaration No. 07764 for Lot No. 5053-H had been canceled and replaced with Tax Declaration No. 23959 in Dionisio's name.
- The change was based on a Deed of Absolute Sale dated June 27, 1956, allegedly executed by Cipriano in favor of Dionisio.
Legal Proceedings
- Petitioners filed a complaint in July 1997 against respondents for quieting of title,