G.R. No. 171497 ; April 4, 2011
MARIA LOURDES TAMANI, CONCEPCION TAMANI, ESTRELLA TAMANI, TERESITA TAMANI, AZUCENA SOLEDAD, DOLORES GUERRERO, CRISTINA TUGADE, DAMIETA MAMSAANG, MANUEL TAMANI, VALERIANA CASTRO, AURORA SANTIAGO and ROSARIO CASTILLO, Petitioners, vs. ROMAN SALVADOR and FILOMENA BRAVO, Respondents.

FACTS

Respondent spouses Roman Salvador and Filomena Bravo filed a complaint for quieting of title against petitioners, the heirs of spouses Demetrio Tamani and Josefa Caddauan, over a 431 sq. m. parcel of land in Solano, Nueva Vizcaya. The parties were co-owners of an undivided 776 sq. m. parcel under TCT No. 8582, with respondents owning 345 sq. m. and the Spouses Tamani owning the disputed 431 sq. m. Respondents claimed that on August 17, 1959, the Spouses Tamani sold the disputed property to Milagros Cruz via a Deed of Absolute Sale. Cruz, in turn, sold the same property to respondents on December 11, 1980. This led to the cancellation of TCT No. 8582 and the issuance of TCT No. T-55328 in respondents’ names for the entire 776 sq. m. Petitioners, as heirs, argued they were the lawful owners and in possession of the property, alleging that Demetrio Tamani’s signature on the 1959 deed was forged. At trial, conflicting expert reports were presented: the NBI report concluded the questioned and standard signatures of Demetrio Tamani were written by the same person, while the PNP report concluded they were written by two different persons. The RTC favored petitioners, declaring both deeds and TCT No. T-55328 null and void, and reinstating TCT No. 8582, giving more weight to the PNP examiner’s credentials. The CA reversed the RTC, declaring the documents valid, finding the similarities between signatures more prominent than the dissimilarities, noting petitioners did not question Josefa Caddauan’s signature, and holding that petitioners failed to overcome the presumption of authenticity of the notarized deed.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s factual findings and in ruling that the signature of Demetrio Tamani on the 1959 Deed of Absolute Sale was genuine, thereby validating the subsequent sale and title.

RULING

The Supreme Court granted the petition and reinstated the RTC decision. The Court held that the conflicting factual findings between the RTC and CA authorized a re-examination of the evidence. The Court found the RTC’s reliance on the PNP examiner’s superior educational and professional background (Master’s degree, professor, more documents examined, more court testimonies) over the NBI examiner was a valid exercise of discretion. The Court emphasized that the burden to prove the signature’s genuineness rested on respondents as the parties relying on the deed. The presumption of authenticity due to notarization is disputable and may be overcome by clear and convincing evidence of forgery. The Court agreed with the RTC that the PNP report, coupled with petitioners’ testimonies and the lack of consideration receipt, sufficiently established forgery. The CA improperly substituted its own judgment on the handwriting analysis despite the RTC’s opportunity to observe the witnesses’ credibility. Thus, the 1959 and 1980 deeds, as well as TCT No. T-55328, were declared null and void, and TCT No. 8582 was reinstated.