Spouses Garrido v. Court of Appeals
REITERATIONFacts
The Antecedents: Tomas Hingco donated one-half of Lot 209 to his stepdaughter Magdalena Rondael, subject to a condition that she could not sell it. Upon Tomas's death, his wife Consolacion inherited the other half, which was later inherited by Magdalena. Thus, Magdalena became the registered owner of the entire Lot 209. In 1973, Magdalena sold a portion of Lot 209. In 1976, her husband Lorenzo died. In 1978, while a petition to cancel the lien prohibiting sale was pending, Magdalena executed a Conditional Deed of Sale for the remaining portion (Lot 209-A) to respondents Spouses Suplemento, subject to the subsisting lien. The agreement stipulated that the purchase price would be refunded if the lien was not cancelled. In 1979, Magdalena's petition to cancel the lien was denied. Despite this, in July 1979, Magdalena executed a Deed of Absolute Sale of Lot 209-A in favor of the Suplementos. Magdalena died in 1982, and the title was issued in the Suplementos' name. Petitioners, Magdalena's daughter and son-in-law, learned of the sale in 1984 and filed a complaint for annulment of the Deed of Absolute Sale, alleging it was fictitious and that Lorenzo Daguro's signature was a forgery as he died prior to its execution. Procedural History: The Regional Trial Court (RTC) declared the sale valid, finding that Magdalena intended to sell the property and that Lorenzo's signature was not necessary for the conveyance of her paraphernal property. However, the RTC ordered the Suplementos to pay petitioners P16,000.00, representing the unpaid balance of the purchase price. The Court of Appeals (CA) affirmed the RTC's ruling. Petitioners appealed to the Supreme Court, contending that the CA erred in holding they had no personality to assail the sale and in ruling on the genuineness of Magdalena's signature. The Petition: Petitioners argued that the CA exceeded its jurisdiction by ruling on their lack of personality to question the non-observance of the donation's condition, which they claimed was beyond the issues raised. They also presented an NBI report, obtained after the CA decision, which purportedly showed Magdalena's signature on the Deed of Absolute Sale was a forgery.
Issue(s)
Whether petitioners have the legal personality to assail the Deed of Absolute Sale and question the violation of the condition in the deed of donation. Whether the NBI report, obtained after the CA decision, constitutes newly discovered evidence that warrants a new trial. Whether the Deed of Absolute Sale is valid despite allegations of forgery and the subsisting lien at the time of its execution.
Ruling
The petition is DENIED. The decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the personality to sue: The Court held that petitioners, as the daughter and son-in-law of the donee, have no personality to question the violation of the restriction imposed in the deed of donation. According to Article 764 of the Civil Code, it is the donor who has the right to impugn the validity of a transaction affecting the donated property due to non-compliance with conditions. While this right can be transmitted to the heirs of the donor, it cannot be exercised by the heirs of the donee. Petitioners are not heirs of the donor, Tomas Hingco, and therefore cannot invoke the donor's right to revoke or question the sale based on the violated condition. The Court reiterated that the right to revoke a donation for breach of condition is personal to the donor and his heirs, not the donee's heirs. On newly discovered evidence: The Court ruled that the NBI report, which was presented for the first time before the Supreme Court, does not qualify as newly discovered evidence. For evidence to be considered newly discovered, it must be discovered after trial, could not have been discovered and produced during trial even with reasonable diligence, and must be material and not merely corroborative or impeaching. Petitioners failed to show they exercised reasonable diligence in procuring such evidence before or during the trial. They could have had Magdalena's signature examined when the case was still with the trial court. The fact that the NBI report was sought by the City Prosecutor in connection with a separate criminal complaint, and even then, the NBI initially could not render a definite opinion due to insufficient basis, further demonstrates petitioners' lack of diligence. On the validity of the sale and forgery allegations: The Court accorded finality to the CA's finding, supported by substantial evidence, that the alleged discrepancy in Magdalena Rondael's signature on the Deed of Absolute Sale did not exist. The burden of proof to establish forgery lies with the party alleging it, and petitioners failed to discharge this burden. The Court noted that petitioners attached receipts purportedly signed by Magdalena, but most were signed "Magdalena Daguro" instead of "Magdalena Rondael," and there was no showing that the signatures presented for comparison were themselves genuine. Conversely, the Deed of Absolute Sale is a notarized document, which carries significant evidentiary weight regarding its due execution. The Court also found that Lorenzo Daguro's signature was not necessary to convey Magdalena's paraphernal property, thus rendering the forgery allegation regarding his signature immaterial to the validity of the sale.
Main Doctrine
Petitioners, not being heirs of the donor, have no personality to question the violation of a condition imposed in a deed of donation. Furthermore, an NBI report on questioned documents, not presented at the trial level and discovered after the period for appeal, cannot be considered newly discovered evidence for purposes of a new trial.