Case Summary (G.R. No. 138777)
Applicable Law
The applicable law in this case is grounded in the 1987 Philippine Constitution, specifically governing property rights, contract validity, and the laws relating to forgery and mortgages.
Factual Background
The respondents own a parcel of land covered by Transfer Certificate of Title (TCT) No. T-101817, issued by the Registry of Deeds of Bulacan. The issue arose when the Spouses Inoncillo, brothers of Archimedes S. Inoncillo, secured a loan of P1,600,000.00 from Planters Development Bank, mortgaging the aforementioned property. The Spouses Inoncillo produced Special Powers of Attorney (SPAs) allegedly from Archimedes, which authorized them to mortgage the property without his knowledge or consent. The respondents only became aware of the mortgage when they returned from the United States in October 1997.
RTC Decision
The Regional Trial Court (RTC) ruled in favor of the respondents, asserting that the SPAs and the mortgage agreement were fraudulent and that the signatures were forged. Evidence presented included the verification from the Register of Deeds and the respondents' testimony affirming their absence from the country during the execution of the documents. The RTC emphasized that Planters Development Bank failed to verify the authenticity of the signatures and therefore could not claim good faith as a mortgagee. The RTC declared the mortgage agreement void ab initio, leading to an injunction against further foreclosure actions, alongside an order for the petitioner to pay attorney's fees and litigation expenses.
Court of Appeals Ruling
On appeal, the Court of Appeals affirmed the RTC’s findings, noting that a lack of forensic examination on signatures did not undermine the RTC’s conclusions. They stated that the RTC was sufficiently capable of assessing the signatures' authenticity based on its personal examination. The appellate court also upheld the award for attorney's fees, recognizing that the respondents were compelled to engage legal counsel due to the dispute.
Supreme Court Ruling
Upon review, the Supreme Court found the petition from Planters Development Bank to have no merit. It held that the question of forgery and signature authenticity presented factual issues that are beyond the Court's scope in a petition for review on certiorari, which is limited to questions of law. The high court reiterated that factual findings of lower courts, particularly when affirmed by an appellate court, enjoy respect and finality.
Decision on Forgery and Evidence
The burden of proof regarding forgery rests with the party alleging it. The Supreme Court noted that the respondents had provided sufficient evidence to establis
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Background of the Case
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner is Planters Development Bank (PDB), now China Bank Savings, Inc.
- The respondents are Spouses Archimedes S. Inoncillo and Liboria V. Mendoza, represented by Roberto V. Aquino.
- The petition challenges the Decision dated June 29, 2018, and the Resolution dated January 10, 2019, of the Court of Appeals (CA), which affirmed the February 8, 2013 Decision of the Regional Trial Court (RTC) of Malolos City, Branch 15.
Factual Antecedents
- The case originated from a complaint filed by the respondent Spouses against PDB and others, seeking annulment of a mortgage, damages, and a preliminary injunction with a temporary restraining order.
- Respondent Spouses claimed ownership of a parcel of land under Transfer Certificate of Title (TCT) No. T-101817.
- The complaint included allegations that the respondent Spouses' signatures were forged on a Special Power of Attorney (SPA) and a mortgage agreement executed to secure a loan taken by the Spouses Inoncillo.
- The loan of P1,600,000.00 was taken by Spouses Inoncillo from PDB, secured by the mortgage over two parcels of land, one of which belonged to the respondent Spouses.
RTC Ruling
- The RTC ruled in favor of the respondent Spouses, finding that the SPA and the mortgage agreement were forged.
- Evidence presented included:
- The authenticity of TCT No. T-101817 was question