G.R. No. 154087. October 25, 2005.
MILAGROS ILAO-QUIANAY and SERGIO ILAO, as Joint Administrator of the Intestate Estate of Simplicio Ilao, and AMBROSIA ILAO, Petitioners, vs. RODOLFO MAPILE, Respondent.

FACTS

The case involves a parcel of land in Manila registered under TCT No. 48529 in the name of the deceased Simplicio Ilao. During the settlement of Ilao’s estate, an adverse claim by Juanito Ibarra was discovered on the title. Respondent Rodolfo Mapile, claiming to be a subsequent buyer from Ibarra, moved to exclude the property from the estate inventory, asserting Ilao had sold it to Ibarra during his lifetime via a 1972 Deed of Absolute Sale. The heirs (petitioners) filed a suit to quiet title. Mapile later filed a separate case for specific performance. The cases were consolidated.
At trial, the authenticity of Ilao’s signature on the 1972 deed was the central controversy. Petitioners presented a handwriting expert who declared the signature a forgery. Respondent presented a rebuttal expert who initially questioned the genuineness of the specimen signatures but, after excluding those specimens, also concluded the signature was forged. The trial court, however, gave greater weight to the notarized deed itself, finding the conflicting expert testimonies inconclusive. It ruled the sale was genuine and validly transferred the property to Mapile.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s ruling that the Deed of Absolute Sale was genuine and that the property was validly transferred to respondent Mapile.

RULING

The Supreme Court reversed the Court of Appeals and ruled in favor of the petitioners. The legal logic centered on the proper evaluation of evidence and the failure of respondent’s claim to meet the required burden of proof. The Court held that the trial court and the CA erred in relying on the disputable presumption of regularity of the notarized deed despite the presence of clear and convincing evidence of forgery and suspicious circumstances surrounding the transaction.
Both expert witnesses, including respondent’s own rebuttal witness, ultimately concluded the signature was forged. This created a scenario where no credible evidence supported the deed’s authenticity. The Court emphasized that a notarized document is not incontrovertible and can be impeached by strong, complete, and conclusive evidence. Furthermore, the factual circumstances overwhelmingly contradicted a valid sale: Ibarra never took possession of the property or the title, real estate taxes remained in Ilao’s name, and no transfer taxes were paid. Ibarra’s prior fraudulent petition to replace the “lost” title, which was proven false when petitioners produced the original, further discredited his and, by extension, respondent’s claim. Consequently, respondent failed to prove the validity of the sale, and the property rightfully remained part of Ilao’s estate.