Heirs of Salud v. Rural Bank of Salinas
REITERATIONFacts
The Antecedents: Corazon Afable Salud (Corazon) was the registered owner of the Silver Coin Bldg. in Rosario, Cavite. In 1996, her adopted daughter, Carmencita, obtained a P2 million loan from the Rural Bank of Salinas, Inc. (RBSI) secured by mortgages on the property. The loan was granted based on a Special Power of Attorney (SPA) purportedly signed by Corazon on August 20, 1996. Corazon died in 1998. In 2000, Corazon's other heir, Deogracias, discovered the mortgage and claimed the SPA was a forgery, asserting that Corazon never authorized the mortgage and that her signature was falsified. Procedural History: Petitioners filed a Complaint for Declaration of Nullity of Deeds of Mortgage and SPA. During pre-trial, the parties agreed to be bound by the findings of a National Bureau of Investigation (NBI) handwriting expert. The NBI report concluded the signature was not Corazon's. The Regional Trial Court (RTC) initially dismissed the complaint, finding the bank manager's testimony (who saw Corazon sign) more credible. However, on reconsideration, the RTC reversed itself and declared the SPA a forgery based on the NBI report. The Court of Appeals (CA) subsequently reversed the RTC's reconsideration, reinstating the dismissal of the complaint. The Petition: Petitioners filed a Petition for Review on Certiorari under Rule 45, arguing that RBSI was judicially estopped from questioning the NBI report due to the pre-trial agreement. They contended that the scientific findings of the NBI should outweigh the 'biased' testimonies of the bank manager and the notary public, and that the CA erred in not conducting its own independent visual analysis of the signatures.
Issue(s)
Whether the parties and the court are bound by the findings of the NBI handwriting expert pursuant to a pre-trial agreement. Whether the petitioners proved the allegation of forgery by clear and convincing evidence.
Ruling
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals' decision, upholding the validity of the Special Power of Attorney and the subsequent mortgage.
Ratio Decidendi
On Issue 1: The Court ruled that courts are not bound by the opinions of handwriting experts. While the Rural Bank of Salinas, Inc. (RBSI) may have agreed to abide by the National Bureau of Investigation (NBI) report, the court cannot be compelled to adopt such findings. Under Rule 132, Section 22 of the Rules of Court, expert evidence is merely one of four non-hierarchical ways to prove handwriting. The Court emphasized that the expert's function is to provide data, but the ultimate conclusion rests with the judge. Stipulations on the binding nature of expert testimony cannot override the court's duty to evaluate the totality of evidence, especially when the expert's testimony is rendered inconclusive during trial. On Issue 2: The petitioners failed to establish forgery by clear and convincing evidence. The NBI report was discredited because the examiner admitted on cross-examination that the questioned signature could have been written by the same person who signed the bank's standard samples. Furthermore, the expert conceded that age and health—Corazon was 77 at the time—naturally cause tremors and variations in handwriting. Conversely, the bank manager, Teodoro Salud, provided direct, credible testimony that Corazon signed the Special Power of Attorney (SPA) in his presence. The notary public, Atty. Trias, also confirmed Corazon's physical presence during the notarization. As a notarized document, the SPA enjoys a presumption of regularity that the petitioners failed to overcome with the now-inconclusive NBI report.
Main Doctrine
Under Philippine Jurisprudence, the genuineness of handwriting may be proved by: (1) a witness who actually saw the person writing; (2) a witness familiar with the handwriting; (3) a comparison by the court; or (4) expert evidence. There is no legal preference or hierarchy among these methods. Consequently, a finding of forgery does not depend entirely on the testimony of handwriting experts, and courts may disregard such expert findings if they are contradicted by direct evidence or rendered inconclusive by the expert's own admissions regarding variables like age and health.