Bucton v. Go
REITERATIONFacts
The Antecedents: The underlying dispute concerns a parcel of land in Cagayan de Oro City, originally registered under Transfer Certificate of Title (TCT) No. T-9830 in the name of Felix M. Bucton. Felix Bucton alleged that his owner's duplicate certificate of title was lost and subsequently fell into the hands of Benjamin Belisario, Josefa Pacardo, and Salome Cabili. These individuals allegedly conspired to unlawfully deprive Felix of his ownership. A Special Power of Attorney (SPA), purportedly signed by Felix and his wife Nicanora, authorized Belisario to sell the property. On the strength of this SPA, Belisario executed a Deed of Absolute Sale in favor of respondents Spouses Gonzalo and Trinidad Go, leading to the cancellation of Felix's title and the issuance of a new one in the Spouses Go's names. Procedural History: The Heirs of Felix M. Bucton filed a complaint for Annulment of the SPA, Deed of Absolute Sale, and TCT No. T-34210, along with a claim for Recovery of Ownership and Possession, against the Spouses Go. They alleged that the signatures on the SPA were forged and, therefore, no valid title was conveyed. The Regional Trial Court (RTC) of Misamis Oriental, Branch 17, dismissed the complaint, finding it barred by laches and prescription, noting the significant delay in filing the legal action after the alleged fraudulent transaction was discovered in 1981. The Court of Appeals affirmed the RTC's decision, holding that the evidence did not preponderantly establish forgery and that the Spouses Go were innocent purchasers for value who could rely on the face of the certificate of title. The Petition: The Heirs of Felix M. Bucton filed this Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court, assailing the Court of Appeals' decision. They raise three main issues: (1) whether the Court of Appeals erred in ruling that the signatures of the Spouses Bucton on the SPA were not forged; (2) whether the Court of Appeals erred in finding that the Spouses Go are innocent purchasers for value; and (3) whether the Court of Appeals erred in holding that their action was barred by laches and prescription. The petitioners argue that testimonial evidence, including that of an expert witness and Nicanora Bucton, sufficiently proved forgery, and that the Spouses Go failed to exercise due diligence as they dealt with an agent and not the registered owner, thus not qualifying as innocent purchasers for value. They also contend that prescription and laches do not apply due to the lack of good faith and just title on the part of the Spouses Go.
Issue(s)
Whether or not the Court of Appeals grievously erred in ruling that the signatures of the Spouses Bucton in the SPA were not forged. Whether or not the Court of Appeals grievously erred in finding that the Spouses Go are innocent purchasers for value. Whether or not the Court of Appeals grievously erred when it held that the action of the Heirs of Felix are already barred by laches and prescription.
Ruling
The Supreme Court granted the petition, reversed and set aside the assailed Decision of the Court of Appeals. The Court declared the SPA as forged, the Spouses Go as not innocent purchasers for value, and the action as not barred by laches and prescription.
Ratio Decidendi
On the issue of forgery of the SPA: The Court found that the evidence preponderantly favored the Heirs of Felix. While a notarized document enjoys a presumption of regularity, this presumption can be rebutted by clear and convincing evidence. The testimony of NBI expert Eliodoro Constantino, who pointed out significant differences between Felix's purported signature on the SPA and his genuine signatures, coupled with Nicanora Bucton's testimony denying the SPA and identifying her husband's signature, was sufficient to overcome the presumption. The Court noted that even if the standard signatures were not perfectly contemporaneous, gross dissimilarities visible to the naked eye do not require expert opinion. Furthermore, the fact that Felix filed a criminal case for falsification against Belisario, Pacardo, and Cabili in 1984, though archived, served as circumstantial evidence casting doubt on the SPA's integrity. The Court held that preponderance of evidence, meaning the greater weight of credible evidence, favored the Heirs of Felix, establishing forgery. On the issue of Spouses Go being innocent purchasers for value: The Court ruled that the Spouses Go failed to prove their status as innocent purchasers for value. While a forged deed can pass title to a buyer in good faith, the burden of proving this status lies with the buyer. The general rule that one can rely on a Torrens title has exceptions, particularly when the buyer has actual knowledge of facts that would impel a reasonably cautious person to inquire further, or knowledge of a defect in the vendor's title. In this case, the Spouses Go dealt not with the registered owner but with an agent, Belisario. An ordinary prudent person would have inquired directly with the registered owner, Felix Bucton, especially since the Spouses Go personally knew the Buctons and Felix and Gonzalo were members of the same organization. Their failure to do so, and instead relying solely on the SPA presented by the agent, demonstrated a lack of prudence. The Court emphasized that dealing with an agent requires the buyer to discover the agent's authority at their peril. Their ignorance of the agent's lack of authority is not an excuse. The fact that Gonzalo only informed Felix after the sale was consummated further indicated a lack of good faith. Therefore, the Spouses Go were chargeable with knowledge of the agent's lack of authority and could not claim the protection afforded to innocent purchasers for value. On the issue of laches and prescription: The Court held that the action was not barred by laches or prescription. For ordinary acquisitive prescription of ten years, good faith and just title are required. Since the Spouses Go failed to establish good faith and their title was based on a spurious SPA, they could not claim ownership through ordinary prescription. For extraordinary acquisitive prescription of thirty years, uninterrupted adverse possession is required. The Spouses Go's possession from March 1981 was interrupted by the filing of the instant case on February 19, 1996, which was only 15 years, falling short of the 30-year requirement. The Court concluded that the appellate court's finding of prescription was erroneously premised on the absence of forgery and the consequent validity of the deed of sale.
Main Doctrine
The Court reversed the Court of Appeals' decision, finding that the Special Power of Attorney (SPA) was forged, the Spouses Go were not innocent purchasers for value due to their failure to exercise due diligence when dealing with an agent, and the action was not barred by laches or prescription.