Bentulan v. Bentulan-Mercado
REITERATIONFacts
The Antecedents: Spouses Florentino Bentulan and Librada Salinas owned a parcel of land with a house. Upon Florentino's death, his share passed to his heirs: widow Librada (5/8) and children Aurelia, Moises, and Conchita (each 1/8). A new title reflected this sharing. Librada later died, followed by Conchita. Aurelia learned in 1980 that a new title, TCT No. 24878, was issued in 1979, making Moises the majority co-owner (6/8) by allegedly acquiring Librada's 5/8 share through a deed of sale dated December 28, 1968, for P3,000, and another deed dated January 3, 1969. Aurelia's signature appeared as a witness on both deeds. Aurelia alleged these deeds were fictitious and Librada's and Conchita's signatures were forged. She claimed Moises fraudulently induced her to sign the private deed in December 1978 by misrepresenting the signatures as genuine and to sign blank sheets of paper for the notarized deed in January 1969, claiming they were for an ejectment suit. Procedural History: Aurelia and Conchita's heirs filed a petition for quieting of title, seeking to declare the deeds of sale and TCT No. 24878 void, and to revive TCT No. 9019. Moises denied the allegations, asserting the validity of the deeds and mentioning an acknowledgment signed by Aurelia and her husband. A supplemental complaint sought a preliminary mandatory injunction to compel Moises to open a locked toilet, which the lower court granted. After several judge changes, the RTC Pasay City, Branch 112, rendered a decision on October 2, 1995, declaring the deeds of sale and TCT No. 24878 null and void, ordering the revival of TCT No. 9019, and awarding damages and attorney's fees. Moises' heirs appealed to the Court of Appeals, which affirmed the RTC decision. Their motion for reconsideration was denied, leading to the present petition for review on certiorari. The Petition: Petitioners (heirs of Moises Bentulan) argue that the Court of Appeals erred in sustaining the trial court's findings of forgery and fraudulent inducement, in affirming the cancellation of TCT No. 24878, and in ruling that the action was not barred by prescription.
Issue(s)
Whether the Court of Appeals erred in sustaining the factual findings of the trial court that the signatures of Librada Salinas on the deeds of sale were forged and that Moises Bentulan fraudulently induced Aurelia Mercado to sign the documents. Whether the Court of Appeals erred in affirming the judgment of the trial court which resulted in the cancellation of TCT No. 24878, considering the validity of the notarized deed of sale and the presumption of validity. Whether the action to quiet title was barred by prescription.
Ruling
The petition is dismissed. The Court of Appeals' Decision dated March 30, 1999, and its Resolution dated May 31, 1999, are affirmed.
Ratio Decidendi
On the issue of forged signatures and fraudulent inducement: The Court held that the first issue raised by the petitioners, concerning the forgery of Librada Salinas' signatures and Moises Bentulan's fraudulent inducement of Aurelia Mercado, involves questions of fact. It is a well-settled rule that findings of fact of the appellate court, which sustain those of the trial court, are binding upon the Supreme Court. The petitioners failed to present any exceptions to this rule. The Court emphasized that while handwriting experts can be helpful, a judge must conduct an independent assessment of the evidence to determine the authenticity of signatures. The NBI expert's report stating no definite opinion could be rendered due to insufficient standards did not preclude the trial court from making its own determination. The Court found no reason to depart from the trial court's conclusion that the signatures were forged and that Aurelia was misled by Moises' misrepresentations. The fact that the judge who rendered the decision did not preside over the entire trial does not invalidate the decision, as the judge can rely on the transcribed stenographic notes and the evidence presented. On the validity of the notarized deed of sale and the presumption of validity, and the resulting cancellation of TCT No. 24878: The Court reiterated that the presumption of validity accorded to public documents, including notarized deeds of sale, is not absolute and can be overcome by clear and convincing evidence to the contrary. The respondents successfully discharged this burden by proving that Aurelia and Pelagio Mercado signed blank pieces of paper upon Moises Bentulan's misrepresentation that they were for an ejectment case. These blank papers were later used to create the notarized deed of sale, which formed the basis for the issuance of TCT No. 24878. The Court found the timeline of events, from the signing of blank papers to the execution of an acknowledgment and the issuance of the new title, indicative of a scheme by Moises Bentulan to acquire a larger portion of the property. On the issue of prescription: The Court clarified that the prescriptive period for an action to annul a contract based on fraud, particularly involving title to real property, commences from the time the document is registered in the office of the register of deeds. This is because registration serves as constructive notice to the whole world, unless the party was already aware of the fraud prior to registration. In this case, TCT No. 24878 was issued on May 21, 1979. The action was instituted on February 22, 1981, which falls well within the four-year prescriptive period from the discovery of the fraud through registration. The Court also found that the Acknowledgment executed by Aurelia and Pelagio Mercado on May 1, 1979, was not an admission of the sale but was obtained under the pretext of securing a loan for Moises, further casting suspicion on its veracity and the timeline presented by the petitioners. Therefore, the action was not barred by prescription.
Main Doctrine
The prescriptive period for an action to annul a contract based on fraud, particularly involving title to real property, commences from the time the document is registered in the registry of deeds, as registration constitutes notice to the whole world, unless the party was already aware of the fraud prior to registration.