GR 149738; (August, 2007) (Digest)
G.R. No. 149738; August 28, 2007
QUINTIN B. BELGICA, Petitioner, vs. MARILYN LEGARDE BELGICA and ANTONIO G. ONG, Respondents.
FACTS
Petitioner Quintin Belgica and his wife, respondent Marilyn Belgica, purchased a conjugal property. While Quintin was abroad, Marilyn, purportedly acting under a Special Power of Attorney (SPA) executed by Quintin, sold the property to respondent Antonio Ong. Upon his return, Quintin filed a complaint for annulment of the deed of sale, claiming his signature on the SPA was forged. To support his claim, he presented an NBI document examiner who, after examining a photocopy of the SPA, reported finding fundamental differences suggesting a different writer, but qualified that a definite determination required analysis of the original.
The respondents presented contrary evidence. They submitted the report of a PNP Crime Laboratory expert who examined the carbon original of the SPA and concluded the questioned and standard signatures were written by the same person. Furthermore, the notary public who notarized the SPA, Atty. Leopoldo Balguma, testified that Quintin signed the document in his presence. The Regional Trial Court dismissed the complaint, finding the SPA signature genuine and the sale valid. The Court of Appeals affirmed this decision.
ISSUE
Whether the Supreme Court can review the factual findings of the lower courts regarding the authenticity of the signature on the Special Power of Attorney.
RULING
The Supreme Court denied the petition. The Court emphasized that a petition for review under Rule 45 is limited to questions of law, not questions of fact. The core issue raised by petitioner—the authenticity of his signature—is a factual question. As a rule, factual findings of the trial court, especially when affirmed by the Court of Appeals, are final, conclusive, and not reviewable by the Supreme Court, provided they are supported by the evidence on record.
The Court found no reason to deviate from this rule. The trial court and the Court of Appeals correctly gave greater weight to the evidence presented by the respondents. The NBI expert’s report was inconclusive, as it was based merely on a photocopy and explicitly stated its findings were “subject to verification.” In contrast, the PNP expert examined the carbon original, which the law regards as an original document, and gave a definitive conclusion of authenticity. This conclusion was strongly corroborated by the clear and positive testimony of the notary public, who had no motive to falsify his testimony. The petitioner’s bare denial of his signature, unsupported by competent evidence, could not overcome this evidence. Therefore, the Supreme Court affirmed the lower courts’ decisions.