Heirs of Demetria Lacsa v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners, heirs of Demetria Lacsa, filed two cases, Civil Case No. G-1190 for recovery of possession with damages and injunction, and Civil Case No. G-1332 for cancellation of title, ownership with damages and injunction. They alleged ownership of a fishpond and open space evidenced by OCT No. RO-1038 (11725) and claimed respondents, without right, occupied the land through stealth and fraud, and that respondents' predecessor, Inocencio Songco, succeeded in transferring the title to his name by presenting forged and simulated documents ('TRADUCCION AL CASTELLANO DE LA ESCRITURA DE PARTICION EXTRAJUDICIAL' and 'ESCRITURA DE VENTA ABSOLUTA') after respondents and their predecessors had occupied and later abandoned the fishpond. Procedural History: Private respondents denied the allegations, asserting that OCT No. RO-1038 (11725) was cancelled and superseded by TCT No. 794 in the name of Alberta Guevarra and Juan Limpin via an extrajudicial partition, which was in turn superseded by TCT No. 929 in the name of Inocencio Songco via a deed of absolute sale, and they counterclaimed for damages. A joint stipulation of facts was filed, agreeing that evidence from Civil Case No. G-1190 would be adopted for both cases, and both cases would be submitted for resolution based on the evidence in G-1190. The Regional Trial Court (RTC) ruled in favor of private respondents, dismissing both complaints and ordering the cancellation of Demetria Lacsa's OCT, restoration of possession to respondents, and payment of damages and attorney's fees. Petitioners appealed to the Court of Appeals (CA), assigning errors regarding the RTC's appreciation of evidence, particularly the alleged forgery and simulation of documents, and its findings on the 'ancient document rule' and the status of Inocencio Songco as an innocent purchaser for value. The CA affirmed the RTC decision with modification, deleting the awards for moral and exemplary damages and attorney's fees, and denied petitioners' motion for reconsideration. The Petition: Petitioners filed a petition for review on certiorari with the Supreme Court, assailing the CA's application of the 'ancient document rule,' disregard of notarial law requirements, and failure to properly rule on proof of public or official records.
Issue(s)
Whether the documents 'TRADUCCION AL CASTELLANO DE LA ESCRITURA DE PARTICION EXTRAJUDICIAL' and 'ESCRITURA DE VENTA ABSOLUTA' qualify as ancient documents under Section 22, Rule 132 of the Rules of Court. Whether the alleged lack of signatures on the first pages of the documents constitutes a fatal flaw that renders them invalid or suspicious. Whether the documents, being over thirty years old and certified copies from the Register of Deeds, require further proof of execution and authenticity. Whether the Court of Appeals erred in applying the 'ancient document rule' and disregarding other alleged mandatory requirements.
Ruling
The petition is denied. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the qualification of the documents as ancient documents: The Supreme Court held that the documents in question, 'Traduccion Al Castellano de la Escritura de Particion Extrajudicial' (Exhibit "3") executed on April 7, 1923, and 'Escritura de Venta Absoluta' (Exhibit "7") executed on January 20, 1924, are indeed more than thirty (30) years old. These documents were certified as exact copies of originals on file with the Register of Deeds of Pampanga, thus satisfying the requirement of being produced from a custody in which they would naturally be found if genuine. The Court found that the certification from the Register of Deeds and the Archives Division of the Bureau of Records Management established their proper repository. Therefore, the first two requirements of the 'ancient document rule' were met. On the alleged lack of signatures and circumstances of suspicion: The Court found that petitioners failed to present conclusive evidence to support their allegation of forgery or simulation. The mere allusion to the lack of signatures on the first pages as a potential for substitution was deemed a surmise without proof. The Court reiterated that a contract appearing honest and lawful on its face must be treated as such, and the burden of proving falsification rests on the party alleging it. The lack of signatures, absent any alterations or circumstances of suspicion, did not detract from the genuineness of the documents, especially since they were certified copies from the Register of Deeds. The 'ancient document rule' refers to the extrinsic quality of the document, and the alleged defect did not present any external blemish or suspicion. On the need for further proof of execution and authenticity: As the documents met the criteria of the 'ancient document rule' – being over thirty years old, from the proper custody, and unblemished by alteration or suspicion – no further proof of their due execution and authenticity was required. Consequently, the Court found no need to resolve the petitioners' contentions regarding the mandatory requirements of the 1903 Notarial Law or the presentation of the public official who issued the certification, as these would no longer serve any purpose given the application of the ancient document rule. On the Court of Appeals' application of the rule: The Supreme Court found no error in the Court of Appeals' application of the 'ancient document rule.' The documents, having met all the requisites, were correctly admitted and given probative value without the need for further authentication. The Court emphasized that the rule exempts such documents from the necessity of proving their execution and authenticity, thereby validating the CA's reliance on them.
Main Doctrine
A private writing more than thirty years old, produced from a custody in which it would naturally be found if genuine, and unblemished by any alteration or circumstances of suspicion, is considered an ancient document and requires no further proof of its execution and authenticity. Allegations of forgery or simulation must be supported by conclusive evidence.