Meneses v. Venturozo
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership of a parcel of untitled coconut land. Respondent Rosario G. Venturozo (plaintiff in the trial court) claimed ownership based on a Deed of Absolute Sale dated January 31, 1973, purportedly from Basilio de Guzman, who in turn allegedly purchased the property from petitioner Adelaida Meneses via a Deed of Absolute Sale dated June 20, 1966. Respondent alleged that petitioner forcibly took possession of the land in May 1983. Petitioner, however, asserted that she never signed the 1966 deed, claiming it was a forgery, and that she inherited the property from her father and had been in possession for over 30 years. She further alleged that the respondent had filed multiple previous cases regarding the same land. 2. Procedural History: Respondent filed a complaint for ownership, possession, and damages against petitioner in the Regional Trial Court (RTC) of Dagupan City. The RTC ruled in favor of petitioner, declaring both deeds of sale null and void, recognizing petitioner as the owner, and ordering respondent to execute a deed of reconveyance and pay damages. Respondent appealed this decision to the Court of Appeals (CA). The CA reversed the RTC's decision, declaring respondent the owner and ordering petitioner to vacate the property. Petitioner's motion for reconsideration was denied by the CA. This led to the present petition for review on certiorari before the Supreme Court. 3. The Petition: Petitioner Adelaida Meneses, substituted by her heir, filed this petition for review on certiorari under Rule 45 of the Rules of Court, raising the sole issue of whether the Court of Appeals' decision was in accordance with law and jurisprudence. Petitioner argues that her admission regarding her signature on the 1966 deed was taken out of context and that the RTC's finding of forgery, based on a comparison of signatures and the credibility of witnesses, should have been given more weight. Petitioner also contends that the notarization of the 1966 deed was defective, rendering it a private document requiring proof by a preponderance of evidence, and that the RTC correctly found her signature to be a forgery based on such evidence.
Issue(s)
Whether the Court of Appeals erred in reversing the Regional Trial Court's decision regarding the validity of the Deed of Absolute Sale dated June 20, 1966, considering its defective notarization. Whether petitioner's signature on the Deed of Absolute Sale dated June 20, 1966, was a forgery, and the impact on the deed's validity. Whether petitioner's alleged admission regarding her signature should be considered a conclusive judicial admission, given her consistent denials and the context of the questioning. Whether the testimony of the Notary Public should be given weight, considering contradictions and the trial court's assessment of credibility, and the overall deference to the trial court's findings on witness credibility.
Ruling
The petition is meritorious. The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Court of Appeals' Decision and Resolution, and REINSTATED the Decision of the Regional Trial Court.
Ratio Decidendi
On the validity of the Deed of Absolute Sale dated June 20, 1966 and the Court of Appeals' error: The Court held that while notarized documents enjoy a presumption of regularity, this presumption can be overcome by clear and convincing evidence. In this case, the notarization of the Deed of Absolute Sale dated June 20, 1966, was defective. The Notary Public signed as one of the two witnesses, leaving only one actual witness. Furthermore, the residence certificate of the petitioner was issued and recorded on June 21, 1966, the day after the deed's execution and notarization. These defects stripped the document of its public character, reducing it to a private instrument, and thus, its validity must be tested by a preponderance of evidence, not the higher standard for public documents. The Court emphasized that a defective notarization dispenses with the clear and convincing evidentiary standard normally attached to duly-notarized documents. The Court reiterated the well-settled doctrine that findings of trial courts on the credibility of witnesses deserve a high degree of respect and the appellate court should have given due weight to these findings. On the genuineness of petitioner's signature and its impact on the deed's validity: The Court agreed with the trial court that petitioner's signature on the Deed of Absolute Sale dated June 20, 1966, was a forgery. A comparison with her specimen signatures and those on other pleadings revealed significant differences, even considering the 17-year gap. The trial court, having observed the witnesses' deportment, found petitioner's testimony credible, and its evaluation of witness credibility is entitled to great respect. The Court found the trial court's finding of forgery to be supported by the evidence presented. On the alleged judicial admission: The Court found that petitioner's admission regarding her signature was taken out of context. Petitioner consistently denied signing the deed, appearing before the notary, or securing the residence certificate in her Answer and testimony. The context of the question asked during her testimony was whether she recognized the signature as hers, not whether she affixed it to the deed. The Court acknowledged the exceptions to the conclusiveness of judicial admissions, particularly when an admission is cited out of context or when it is shown that no such admission was actually made. Given her consistent denials and the trial court's finding of credibility, the alleged admission was deemed unreliable. On the testimony of the Notary Public and deference to the trial court's findings: The Court found the Notary Public's testimony self-serving and unreliable. There was a contradiction between his testimony and that of respondent's mother regarding who obtained and submitted the residence certificate. This contradiction cast doubt on whether the Notary Public truly knew the identity of the vendor who signed the deed on June 20, 1966. The Court gave more weight to the trial court's assessment of credibility, which favored petitioner's version of events.
Main Doctrine
A defective notarization strips a document of its public character, reducing it to a private instrument, and the measure to test its validity becomes preponderance of evidence. Furthermore, a judicial admission taken out of context, especially when contradicted by the party's consistent assertions and the trial court's findings, may be disregarded.