Carbonell v. Carbonell-Mendes
REITERATIONFacts
The Antecedents: The underlying dispute concerns the validity of a Deed of Absolute Sale dated April 2, 1997, and the subsequent Transfer Certificate of Title (TCT) No. T-51120 issued in the names of Spouses Bonifacio and Janet Carbonell. Respondent Julita A. Carbonell-Mendes, who resides in Canada, alleged that the Deed of Absolute Sale was fictitious and her signature thereon was forged. She claimed to be the rightful owner of the property covered by TCT No. T-45306, which was allegedly cancelled and replaced by TCT No. T-51120 based on the simulated sale. The respondent also accused the Rural Bank of Bayambang, Pangasinan, where the property was mortgaged by the Spouses Carbonell, of being a mortgagee in bad faith, though this claim was later dismissed after the mortgage was settled. Procedural History: Respondent Julita A. Carbonell-Mendes initiated a complaint for Declaration of Nullity of Documents, Annulment of Title, Reconveyance, Recovery of Possession and Ownership, Declaration of Bad Faith of Mortgage Bank and Damages before the Regional Trial Court (RTC) of Rosales, Pangasinan. The RTC, after trial, rendered a decision on June 26, 2009, declaring the Deed of Absolute Sale fictitious and of no force and effect, invalidating TCT No. T-51120, and ordering the restoration of TCT No. T-45306. The RTC also ordered the Spouses Carbonell to surrender the owner's copy of TCT No. T-51120, reconvey possession of the property, and pay attorney's fees. Petitioner Janet Carbonell appealed this decision to the Court of Appeals. The Court of Appeals, in its Decision dated July 4, 2012, affirmed the RTC's ruling in toto. Petitioner's subsequent motion for reconsideration was denied by the Court of Appeals in a Resolution dated January 16, 2013. The Petition: Petitioner Janet Carbonell filed the present petition for review on certiorari under Rule 45 of the Rules of Court, assailing the decision and resolution of the Court of Appeals. The core of petitioner's argument is that the Court of Appeals erred in affirming the RTC's finding of forgery on the Deed of Absolute Sale. The Supreme Court, however, found the petition to be without merit, noting that the issue of forgery is a question of fact, and Rule 45 petitions are generally limited to questions of law. The Court reiterated that factual findings of the trial court, when affirmed by the Court of Appeals, are binding and conclusive, and found no exceptional circumstances to deviate from this rule. The Court also found that the evidence presented, including a comparison of signatures and proof of the respondent's absence from the country during the execution of the deed, sufficiently supported the conclusion of forgery.
Issue(s)
Whether the Court of Appeals erred in affirming the RTC's finding of forgery on the Deed of Absolute Sale. Whether the petition raises a question of law or fact.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the petition primarily raises a question of fact, which is generally beyond the scope of a petition for review on certiorari under Rule 45, and that no exceptions to this rule were demonstrated. The Court found no reason to deviate from the concurrent findings of the RTC and the CA that the signature of the respondent on the Deed of Absolute Sale was forged, as this was clearly established by the evidence presented.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the RTC's finding of forgery on the Deed of Absolute Sale: The Court found no merit in the petition. It reiterated the well-settled rule that factual findings of the trial court, when affirmed by the Court of Appeals, are binding and conclusive. The Court emphasized that its role under Rule 45 is generally limited to reviewing errors of law, not fact. Petitioner failed to show that the case falls under any of the recognized exceptions to this rule, such as grave abuse of discretion or a misapprehension of facts. The Court found no justifiable reason to deviate from the concurrent findings of the RTC and the CA that the signature of respondent on the Deed of Absolute Sale dated April 2, 1997, was forged. This forgery was clearly established by the evidence presented during the trial. Under Section 22, Rule 132 of the Rules of Court, handwriting can be proven by a witness familiar with it or by comparison by the court with genuine specimens. In this case, respondent testified that her signature was forged and presented various documents (passports, driver's license, citizenship card, health card) bearing her genuine signature, which were clearly different from the signature on the Deed of Absolute Sale. The RTC, through its own examination, found significant differences in handwriting strokes, shapes, and letter sizes, indicating that respondent was not the author of the questioned signature. The Court cited Spouses Estacio v. Dr. Jaramillo to support the trial court's authority to determine forgery from its own visual comparison of signatures without necessarily resorting to handwriting experts. On the issue of whether the petition raises a question of law or fact: The Court determined that the petitioner's submission, which questions the CA's affirmation of the RTC's finding of forgery on the Deed of Absolute Sale, is fundamentally a question of fact. A question of fact requires a review of the evidence presented, which is not the function of the Supreme Court in a petition for review on certiorari under Rule 45. The Court reiterated that Rule 45 is designed to pass upon questions of law, not to re-examine or re-evaluate evidence. The exceptions to this rule, such as conflicting findings of fact, manifest error, or grave abuse of discretion, were not shown to be present in this case. Therefore, the Court was constrained to uphold the factual findings of the lower courts, as they were supported by substantial evidence and affirmed by both the RTC and the CA.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' ruling that a Deed of Absolute Sale was fictitious and its supporting Transfer Certificate of Title (TCT) invalid, based on substantial differences in handwriting, the signatory's absence from the country during the sale's execution, and the failure of the defense to present sufficient evidence to substantiate their claim of purchase.