Title
Conchita Juachon, in her capacity as guardian of the persons and estate of the minors, Ricardo and Edgardo Ocampo vs. Felix Manalo
Case
G.R. No. L-42
Decision Date
Jan 20, 1947
Conchita Juachon, as guardian, contested a deed of sale allegedly forged by Soledad Tinio. The Supreme Court ruled the deed invalid due to proven forgery, granting Juachon standing to annul the sale.

Case Summary (G.R. No. 127997)

Summary of Proceedings

The case is an appeal to reverse a judgment by the Court of First Instance of Manila, which dismissed the complaint for the annulment of a deed of sale dated January 14, 1945, executed by Soledad Tinio. The trial court concluded that there was insufficient evidence to ascertain the deed's authenticity, and thus ruled in favor of the defendant, Felix Manalo, imposing costs on the plaintiff. The plaintiff contended that the deed was invalid as it bore the forged signature of Soledad Tinio, who had died shortly after the purported sale.

Allegations of Forgery

The plaintiff asserts that on the date of the sale, Soledad Tinio was not present in Manila and claims she explicitly denied the intention to sell the property. A handwriting expert testified that there were significant differences between the genuine signatures of Soledad Tinio and those found on the deed of sale, leading to the conclusion that the signatory on the deed could not have been Soledad Tinio. The expert noted differences in the writing style and characteristics of the signatures.

Testimonies and Evidence

Despite the expert analysis pointing toward forgery, the trial court considered testimonies from the notary public and instrumental witnesses who attested to the legitimacy of the deed. The notary stated that four individuals, including Soledad Tinio, acknowledged the deed of sale on January 18, 1945, which was four days post-signing. The court regarded their testimonies as crucial, negating the expert’s findings due to the witnesses’ claims of having seen Soledad sign the document.

Discrepancies in Statements

The credibility of the testimonies presented was called into question. The witness, Jose Lukban, provided conflicting statements about his prior knowledge of Soledad Tinio and the signing process, which eroded his reliability as a witness. Furthermore, the trial court noted the absence of the Torrens title during the acknowledgment process, raising further doubts regarding the transaction’s legitimacy.

Observations of the Court

The court recognized the significant role played by Alejandro Regala, Soledad Tinio's husband. It highlighted that Regala initiated the sale and received the considerable purchase price, fostering skepticism about the genuine nature of

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