Case Summary (G.R. No. 163271)
Factual Antecedents
Julian Sambaan, married to Guillerma Saarenas-Sambaan, had registered ownership of a property identified as TCT No. T-14202, describing an area of 3,643 square meters. The Sambaan siblings, including Myrna Bernales (the eldest), were involved in a familial conflict regarding the property. Allegedly, in 1975, Julian expressed wishes concerning the property while hospitalized, urging his children to redeem it from the petitioners, who had mortgaged it. In 1991, the heirs discovered that the property title had been transferred to the petitioners through a Deed of Absolute Sale dated December 7, 1970, which they later proved was based on forged signatures.
Proceedings before the Regional Trial Court
On April 13, 1993, the respondents filed a complaint seeking the annulment of the Deed of Absolute Sale and a cancellation of TCT No. T-14204, alleging forgery. The petitioners responded with claims of their legitimate ownership of the property, detailing a complex history of transactions involving Julian’s inheritance and transfers. After thorough proceedings, the Regional Trial Court ruled in favor of the respondents, declaring the sale null and void and ordering the issuance of a new title in Julian's name.
Proceedings before the Court of Appeals
The petitioners appealed the trial court’s decision, arguing various errors regarding the appreciation of evidence and the courts' findings relating to the signatures in question. The Court of Appeals upheld the trial court's ruling, affirming the decision based on substantial evidence presented.
Issues Raised
In their Petition for Review, the petitioners contended that: A) The Court of Appeals erroneously ruled that the action to recover ownership was not barred by prescription. B) It disregarded expert witness testimony regarding the authenticity of the signatures. C) It ruled without proper appreciation of the evidence of forgery provided. D) It failed to consider a legally relevant agreement confirming the ownership of the property. E) It incorrectly maintained the award of damages to the respondents.
Our Ruling
The resolution primarily concerns the authenticity of the Deed of Absolute Sale and the determination of whether the petitioners held valid title. Recognizing the errors in the petitioners' interpretation of the appellate court's findings, the Supreme Court emphasized that matters relating to factual determinations are generally not suited for review unless there are compelling reasons to deviate. The Court reaffirmed that substantial evidence supported the conclusion that the signatures were forged, bolstered by scientific findings from the National Bureau of Investigation (NBI) and corroborated testimony.
Findings on Forgery and Title
The substantive findings pointed out that both Julian and Guillerma’s signatures were established to be forgeries, rendering the Deed of Absolute Sale invalid. Consequently, the petitioners’ claims to rights over the property based on said deed were nullified under principles established in previous rulings conc
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Case Background
- This case revolves around a family dispute regarding a parcel of land situated in Bulua, Cagayan de Oro City, which was the subject of a Deed of Absolute Sale.
- The petitioners, Spouses Patricio and Myrna Bernales, claimed ownership based on this deed, while the respondents, heirs of Julian Sambaan, contested the sale, alleging forgery of their parents' signatures.
Factual Antecedents
- Julian Sambaan and Guillerma Saarenas-Sambaan were the registered owners of the property, with a Transfer Certificate of Title (TCT) No. T-14202 issued on March 8, 1972.
- The property measures approximately 3,643 square meters.
- In 1975, after an ambush, Julian expressed his wishes to his children regarding the redemption of the property and his funeral arrangements.
- In 1991, the respondents discovered that the property had been transferred to the petitioners’ name and alleged forgery of their parents’ signatures on the Deed of Absolute Sale dated December 7, 1970.
Proceedings Before the Regional Trial Court
- The respondents, along with their mother Guillerma, filed a complaint for annulment of the Deed of Absolute Sale and cancellation of the TCT, as well as damages.
- The petitioners contested the claims, asserting that the property was originally part of a