Aldemita v. Silva
REITERATIONFacts
The Antecedents: Respondents, the Heirs of Melquiades Silva, filed a Complaint for Quieting of Title against the Heirs of Dionisia Vda. De Zabate and petitioner Benzon O. Aldemita. The property in question is Lot 11330 of Pcs-945. Petitioner admitted that the lot was registered in the name of Melquiades Silva and that respondents were in actual possession, except for a 2,000 square meter portion claimed by petitioner. Petitioner also admitted that a document denominated "Kalig-onan sa Palit" was forged. However, he claimed another document, "Kalig-onan sa Panagpalit nga Dayon," and a Deed of Confirmation of Previous Deed of Sale were valid. Procedural History: The RTC appointed the PNP Regional Crime Laboratory Office VII as commissioner to determine the genuineness of signatures on the questioned documents. The report found the signatures on "Kalig-onan sa Panagpalit nga Dayon" and the Deed of Confirmation of Previous Deed of Sale to be forgeries. The parties agreed to consider this report as findings of fact. Petitioner, through new counsel, filed a Motion to Dismiss for lack of cause of action after the case was submitted for decision, which the RTC denied for being filed out of time and for other grounds. The RTC subsequently rendered a Decision declaring respondents as rightful owners, nullifying the questioned documents, and ordering petitioner to vacate. The Court of Appeals affirmed the RTC Decision in toto. The Petition: Petitioner filed a Petition for Review on Certiorari before the Supreme Court, questioning the CA's affirmation of the RTC's decision, primarily on the grounds that respondents failed to prove they were declared legal heirs and that the nullified documents should not have been declared void.
Issue(s)
Whether the respondents, as heirs of Melquiades Silva, have the legal standing to file an action for quieting of title without a prior declaration of heirship. Whether the Court a quo erred in declaring the documents "Kalig-onan sa Panagpalit nga Dayon," Deed of Confirmation of Previous Deed of Sale, and Deed of Absolute Sale null and void.
Ruling
The petition is denied, and the assailed Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of respondents' legal standing: The Supreme Court held that the petitioner's motion to dismiss for lack of cause of action was filed out of time. Under Section 1, Rule 16 of the Rules of Court, such a motion must be filed within the time for but before filing the answer to the complaint. Petitioner's motion was filed after the case was submitted for decision, thus constituting a waiver of the ground. Furthermore, the Court noted that the issue of respondents' legal standing was not raised in the RTC before the case was submitted for decision and was raised for the first time on appeal, which cannot be resolved without offending basic rules of fair play. Even if considered, the RTC correctly pointed out that the heirs of Melquiades Silva were suing through the administrator of the estate, and a declaration of heirship was not strictly necessary at that stage, especially since the case was submitted for decision without trial. The Court reiterated that the capacity of the heirs to sue was not questioned during pre-trial or in the petitioner's position paper. On the issue of the validity of the documents: The Supreme Court affirmed the findings of the RTC and CA that the documents "Kalig-onan sa Panagpalit nga Dayon" and the Deed of Confirmation of Previous Deed of Sale were forged. This was based on the report of the court-appointed commissioner, which the parties agreed to consider as findings of fact. Petitioner's contention that "Kalig-onan sa Panagpalit nga Dayon" qualified as an ancient document and thus did not require proof of authenticity was rejected. The Court emphasized that even ancient documents require proof of due execution and authenticity, especially when their genuineness is questioned and found to be forged by a commissioner. Since the parties agreed to submit the case for decision without trial, and petitioner failed to present evidence to prove the authenticity of these documents after the forgery was established, he could not later question the RTC's findings. Consequently, the Deed of Absolute Sale executed by Emilia Deiparine in favor of petitioner, based on these void documents, had no legal basis and could not transfer any rights.
Main Doctrine
A motion to dismiss based on lack of cause of action must be filed within the time for but before filing the answer to the complaint, and failure to do so constitutes waiver of such ground, except for specific exceptions not present in this case. Furthermore, the validity of documents, especially when found to be forged by a court-appointed commissioner and agreed upon by the parties as findings of fact, cannot be questioned on appeal.