Coronel v. Quesada
REITERATIONFacts
The Antecedents: Spouses Asuncion and Reynaldo Coronel (Spouses Coronel) filed a complaint for annulment of deeds, cancellation of title, recovery of possession, reconveyance, and damages against Corazon Solis-Quesada (Quesada). The Spouses Coronel alleged ownership of a property covered by TCT No. 156304. They claimed to have allowed Asuncion's aunt, Catalina Hernando, to construct a house on a portion of the property and act as caretaker, entrusting the title and documents to her. Catalina's granddaughter, Mina M. Delos Reyes (Delos Reyes), allegedly obtained the title and mortgaged the property without their consent. The Spouses Coronel discovered a Deed of Donation purportedly from them to Delos Reyes, leading to the cancellation of their title and issuance of TCT No. 292249 in Delos Reyes' name. Subsequently, Delos Reyes and her husband, Rodrigo A. Rodrigo, allegedly sold the property to Quesada via a Deed of Absolute Sale dated June 16, 2000, resulting in TCT No. 335024 in Quesada's name. The Spouses Coronel denied executing the Deed of Donation, claiming it was falsified, and the Deed of Absolute Sale was forged as Rodrigo was in Hawaii at the time. They alleged collusion between Delos Reyes and Quesada. Procedural History: Quesada maintained she was a purchaser in good faith and for value. She claimed the Spouses Coronel executed a Deed of Donation in favor of Delos Reyes, who later mortgaged the property. After foreclosure, Quesada allegedly assisted Delos Reyes in redeeming the property, and then purchased it. The Regional Trial Court (RTC) granted Quesada's Motion to Dismiss on Demurrer to Evidence, finding the complaint dismissible due to prescription and insufficiency of evidence. The Court of Appeals (CA) affirmed the RTC's decision, holding that the Spouses Coronel failed to establish the requisites for reconveyance, prove forgery, or demonstrate Quesada's lack of good faith. The CA also found the action had prescribed. The CA denied the Spouses Coronel's Motion for Reconsideration. The Petition: The Spouses Coronel filed a petition for review on certiorari, questioning the CA's review of factual findings and seeking to establish the sufficiency of their evidence for reconveyance.
Issue(s)
Whether the petition for review on certiorari allows a review of the factual findings of the lower courts. Whether the evidence presented by the petitioners is sufficient to sustain an action for reconveyance, and whether the Deed of Donation and the Deed of Absolute Sale were forged. Whether the action for reconveyance has prescribed. Whether respondent Quesada is an innocent purchaser for value. Whether the questioned documents are public documents.
Ruling
The petition is denied. The Decision of the Court of Appeals affirming the RTC's dismissal of the complaint is affirmed.
Ratio Decidendi
On the scope of review in a petition for review on certiorari: The Supreme Court reiterated that a petition for review on certiorari under Rule 45 of the Rules of Court generally limits its review to questions of law, and factual findings of the lower courts are generally binding and conclusive. While exceptions exist, such as when the findings are not supported by evidence or when there is a misapprehension of facts, the present case did not fall under these exceptions. The Court found no compelling reason to deviate from the factual conclusions reached by the RTC and affirmed by the CA. The core of the Spouses Coronel's claim revolved around allegations of forgery and fraud, which are essentially questions of fact that require a thorough examination of evidence. The Court's role is to determine if the lower courts correctly applied the law based on the established facts, not to re-evaluate the evidence itself unless the circumstances warrant it. On the sufficiency of evidence for reconveyance and the issue of forgery: The Court held that the Spouses Coronel failed to present sufficient evidence to prove their cause of action for reconveyance. Specifically, they failed to substantiate their claim of forgery of the Deed of Donation and the Deed of Absolute Sale. The Court emphasized that forgery cannot be presumed and must be proven by clear, positive, and convincing evidence. Asuncion's self-serving testimony and mere denial, without corroboration from an expert witness or comparison with genuine signatures executed at the closest possible time, were deemed insufficient. The Court noted the significant time disparity between the questioned deeds and the signatures on the pleadings, rendering the comparison unreliable. Similarly, for Rodrigo's signature, the presented evidence was not contemporaneous with the deed, and he admitted to using different signatures. Therefore, the alleged forgery was not sufficiently established. On the issue of prescription: The Court found that the action for reconveyance, as based on alleged void or inexistent contracts due to forgery, should have been filed within ten years from the issuance of the certificate of title. The Spouses Coronel claimed possession, which would render the action imprescriptible if based on an implied trust. However, their claim of possession was contradicted by the testimony of their own witness, Arsenio Antonio, who stated that Delos Reyes and her family lived on the property and that he was only aware of the Spouses Coronel owning the lot at the back. Furthermore, the Spouses Coronel failed to present evidence of their possession prior to August 2010. Given the failure to prove forgery and the lack of continuous possession, the action was deemed to have prescribed. On the status of respondent Quesada as an innocent purchaser for value: The Court found no sufficient evidence to prove that Quesada was not an innocent purchaser for value. While the Spouses Coronel alleged a close relationship between Quesada and Delos Reyes, indicating collusion, this was considered purely speculative. The Court reiterated that a person dealing with registered land may rely on the certificate of title. There was nothing on the title to indicate any defect or encumbrance. The Spouses Coronel failed to present evidence that Quesada had actual knowledge of any defect in Delos Reyes' title or circumstances that would have compelled her to make further inquiries. The allegations of collusion were not substantiated by concrete proof. On the nature of the questioned documents as public documents: The Court affirmed the presumption of regularity attached to notarized documents. The Spouses Coronel's bare denial of appearing before the notary public, without clear and convincing evidence, was insufficient to overcome this presumption. The Court also noted that the issue of non-compliance with formalities for public documents was raised for the first time on appeal, violating basic rules of fair play and due process, as it was not raised in the lower courts or during the trial.
Main Doctrine
The burden of proving forgery lies with the party alleging it and must be established by clear, positive, and convincing evidence. Mere denial and unsubstantiated allegations of variance in signatures are insufficient to overcome the presumption of regularity of notarized documents. Furthermore, the timeliness and relevance of signature exemplars used for comparison are crucial for accurate analysis.