Domingo v. Domingo
REITERATIONFacts
The Antecedents: The underlying dispute concerns the validity of a Deed of Absolute Sale executed on December 28, 1970, by Bruno B. Domingo, the registered owner of a house and lot in Quezon City, conveying the property to his children: Leonora, Nuncia, Abella, and Jose. The petitioner, Turadio C. Domingo, the eldest son, alleges that his father's signature on the deed was forged. A family quarrel ensued over the purported sale, which resulted in the cancellation of the original title and the issuance of a new one in the names of the private respondents. The petitioner also claims the sale violated a restriction on the title requiring prior approval from the People's Homesite and Housing Corporation (PHHC). Procedural History: The petitioner's complaint for the nullity of the deed of sale, reconveyance, and cancellation of title was filed with the Regional Trial Court (RTC) of Quezon City. The RTC dismissed the complaint, disregarding conflicting forensic reports from the PC-INP Crime Laboratory (which found the signature forged) and the National Bureau of Investigation (NBI) (which found it genuine). The trial court found the standard signatures used by the PC-INP to be too old for accurate comparison and that the petitioner failed to prove the need for PHHC approval. The petitioner appealed to the Court of Appeals (CA), which affirmed the RTC's decision. The CA also denied the petitioner's motions for new trial, finding that the newly discovered evidence (a letter from Bruno B. Domingo to PHHC and PHHC's reply) could have been discovered earlier with reasonable diligence and was unlikely to change the outcome. The Petition: The petitioner seeks review of the CA's decision under Rule 45 of the Rules of Court. He argues that the Deed of Absolute Sale is invalid because his father's signature was forged, as indicated by the PC-INP report, and that the sale violated the PHHC restriction and was made within a prohibited period. He also points to his father's subsequent request to mortgage the property as evidence that he had not sold it. The core issue presented to the Supreme Court is whether the lower courts erred in disregarding the PC-INP questioned document report and in upholding the validity of the sale.
Issue(s)
Whether the trial court erred in disregarding the conflicting PC-INP and NBI questioned document reports. Whether the genuineness of Bruno B. Domingo's signature on the Deed of Absolute Sale was sufficiently proven. Whether the Deed of Absolute Sale was executed in violation of the restriction annotated at the back of Bruno's title requiring prior approval from the People's Homesite and Housing Corporation (PHHC).
Ruling
The petition is denied, and the Decision of the Court of Appeals is affirmed. The Deed of Absolute Sale is declared valid.
Ratio Decidendi
On the issue of disregarding conflicting questioned document reports: The Supreme Court affirmed the appellate court's finding that the trial court correctly disregarded the PC-INP Crime Laboratory's questioned document report. The appellate court noted that the standards of comparison used by the PC-INP (documents from 1958 and 1962) preceded the questioned deed (executed in 1970) by more than eight years. The Court reiterated that for accurate handwriting analysis, the standards of comparison must be as close as possible in point of time to the suspected signature, as age and time can influence handwriting characteristics. Therefore, the PC-INP's finding was deemed questionable, and neither the trial court nor the appellate court could be faulted for refusing to give it weight. The NBI's conclusion, which found the signature genuine, was implicitly given more weight due to the proper use of standards or other factors not detailed but leading to the dismissal of the criminal complaint. On the genuineness of Bruno B. Domingo's signature: The Court sustained the trial court and the Court of Appeals regarding the testimonies of Clerma Domingo, Leonora, and Jose, who testified that they saw Bruno affix his signature to the questioned deed. These testimonies were unrebutted. The Court cited Rule 132, Section 22 of the Rules of Court, which allows proof of handwriting by a witness who actually saw the person write. The petitioner failed to show any reason to disturb the trial court's findings on the credibility of these witnesses, as trial courts are in a better position to observe their demeanor and manner of testifying. Furthermore, the Deed of Absolute Sale is a notarized document, which, as a public document, enjoys a presumption of regularity and is prima facie evidence of the facts stated therein. To overcome this presumption, evidence must be clear, convincing, and more than merely preponderant, which the petitioner failed to provide. On the violation of the restriction annotated at the back of the title: The trial court found that the petitioner failed to substantiate his claim that prior PHHC approval was needed before a valid sale could be made. The petitioner's argument that Bruno's request to mortgage the property in 1972 indicated he did not sell it in 1970 was not given decisive weight. The Court of Appeals, in denying the motion for new trial, noted that the letter from Bruno to PHHC requesting permission to mortgage could have been discovered and produced prior to the trial with reasonable diligence. The Court found no reason to overturn the lower courts' findings that the petitioner failed to prove the alleged violation of the PHHC restriction or that the sale was invalid on this ground. The presumption of regularity of the notarized deed and the unrebutted testimonies of witnesses who saw Bruno sign were sufficient to uphold the validity of the sale.
Main Doctrine
A notarized document, being a public document, enjoys the presumption of regularity and is prima facie evidence of the facts therein expressed. To contradict this, evidence must be clear, convincing, and more than merely preponderant. Furthermore, for handwriting analysis, standard signatures used for comparison must be as close as possible in point of time to the suspected signature to ensure accuracy.