Reyes v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondents alleged that a Deed of Extrajudicial Partition and Settlement dated July 29, 1970, purportedly partitioning a parcel of land registered in the name of their deceased father, Bernardino Reyes, was fraudulently prepared by petitioner Florentino Reyes. The Deed allegedly showed private respondents waiving their rights in favor of Florentino, except for Paula Reyes Palmenco who was given a 50-square meter share. Florentino registered the Deed and obtained a new title in his name for 333 square meters and 50 square meters for Paula Palmenco. In May 1985, private respondents discovered the Deed, denied its execution and their signatures, claiming forgery. They also questioned the notary public's commission. Subsequently, Florentino sold portions of the land to his children and executed a Deed of Co-owners' Partition with his children and Paula Palmenco. Procedural History: Private respondents filed a Complaint for Annulment of Sale and Damages, later amended to pray for the annulment of the Deed of Extrajudicial Partition and Settlement, the resulting Transfer Certificate of Title (TCT) No. 318944, a Deed of Absolute Sale, a Deed of Co-owners' Partition, and seven other TCTs issued to Florentino and his children. The Regional Trial Court (RTC) ruled that the signatures on the Deed of Extrajudicial Partition and Settlement were forged and simulated, permanently enjoining the Register of Deeds from issuing TCTs and enjoining petitioners from collecting rentals. The RTC declared the Deed of Extrajudicial Partition and Settlement, TCT No. 318944, the Deed of Absolute Sale, the Deed of Co-owners' Partition, and the seven other TCTs null and void. The Court of Appeals affirmed the RTC decision. The Petition: Petitioners seek the reversal of the Court of Appeals' decision, assigning errors in the findings of forgery, the failure to find acquisitive prescription, and the dismissal of their counterclaims.
Issue(s)
Whether the Deed of Extrajudicial Partition and Settlement was a forgery. Whether petitioner acquired ownership of the land through acquisitive prescription despite the alleged forgery. Whether the complaint should be dismissed and reliefs granted to petitioners' counterclaims.
Ruling
The petition is DISMISSED. The Court of Appeals did not commit reversible error in affirming the decision of the Regional Trial Court.
Ratio Decidendi
On the issue of forgery: The Court affirmed the findings of the lower courts that the Deed of Extrajudicial Partition and Settlement was forged and simulated. This conclusion was based on several factual findings: the signatures appeared to be written by the same hand, the notary public was not commissioned at the time and place indicated, the place of notarization was altered, and the residence certificates were in the possession of the petitioner, which is unnatural. The Court emphasized that factual findings of the RTC, affirmed by the Court of Appeals, are generally conclusive and not subject to review, unless exceptions apply, which were not demonstrated by the petitioners. The Court found the petitioners' arguments, such as the similarity of signatures and the existence of public documents, insufficient to overcome the evidence of forgery. On the issue of acquisitive prescription: The Court rejected the petitioners' claim of ownership through acquisitive prescription. Petitioners could not have possessed the property in good faith because the Deed of Extrajudicial Partition and Settlement, which formed the basis of their alleged just title, was found to be forged from the outset. Possession based on a forged document is considered in bad faith. Furthermore, the property in dispute was titled property registered in the name of the deceased father, Bernardino Reyes. Acquisitive prescription cannot defeat the real rights of the private respondents as successors-in-interest to their father's property. The Court also noted that petitioners could not claim adverse possession as private respondents also resided on the subject property. On the issue of counterclaims and dismissal of the complaint: Since the main issues regarding the forgery of the Deed and the inapplicability of acquisitive prescription were resolved against the petitioners, their counterclaims, which were premised on the validity of the Deed and their alleged ownership, were necessarily dismissed. The Court found no reversible error in the lower courts' decisions to declare the Deed of Extrajudicial Partition and Settlement, the subsequent titles, and deeds of sale as null and void, and to dismiss the petition.
Main Doctrine
A forged deed, being a nullity, cannot serve as a just title for acquisitive prescription, and possession based on such a forged document is considered in bad faith. Furthermore, acquisitive prescription cannot defeat the real rights of successors-in-interest over titled property.