G.R. No. 140472 ; June 10, 2002
NORA T. JIMENEZ, JOSEFINA T. GAVINO, LIBRADA T. DINO and SUSAN T. JOVEN, petitioners, vs. COMMISSION ON ECUMENICAL MISSION AND RELATIONS OF THE UNITED PRESBYTERIAN CHURCH IN THE UNITED STATES OF AMERICA, UNITED CHURCH OF CHRIST IN THE PHILIPPINES and POLICARPIO CARUNGIN, respondents.

FACTS

Petitioners, heirs of spouses Nicanor Teodoro and Francisca Ciriaco, filed a complaint in 1982 seeking the annulment of a 1936 Deed of Sale covering a parcel of land originally registered in their mother’s name. They alleged that their parents’ signatures on the deed, which conveyed the property to the Board of Foreign Missions (predecessor of respondent UCCP), were forgeries. They relied on handwriting reports from the NBI and PC Crime Laboratory supporting this claim. Petitioners asserted they only discovered the sale in 1975 and that their father, before his death in 1979, denied signing the document.
Respondents maintained the deed was valid, asserting the property was purchased in good faith and a church had been constructed and continuously used on the lot since 1936. They argued the action was barred by prescription and laches, as petitioners waited 45 years from the execution of the deed (or decades from their parents’ deaths) to file suit. The trial court initially dismissed the complaint on grounds of prescription and laches but, on motion for reconsideration, reversed itself, declared the deed void due to forgery, and ordered reconveyance.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s finding that the signatures on the 1936 Deed of Sale were forged.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. While factual findings of the trial court are generally respected, this rule yields when the assessment is based on documentary evidence equally available to appellate courts, such as the disputed signatures. The Court exercised its authority to review the conflicting factual assessments.
The Court upheld the CA’s finding that the deed was authentic. First, the deed was a notarized document, enjoying the prima facie presumption of regularity and due execution, which petitioners failed to overcome with clear and convincing evidence. Second, the CA correctly found the expert opinions on forgery inconclusive and insufficient to overturn this presumption. The CA noted inconsistencies in the experts’ findings and gave more weight to the credible testimonies of respondents’ witnesses, including a pastor who attested to the church’s long-standing possession. Third, the petitioners’ inaction for decades—during which a church openly occupied the land—severely undermined their claim and supported the defense of laches. The Court emphasized that preponderance of evidence is determined by quality, not merely the number of witnesses. The totality of evidence sustained the validity of the 1936 sale.