GR 178652; (December, 2010) (Digest)
G.R. No. 178652 ; December 8, 2010
SPOUSES REVELO VILLAMAR and CORAZON PENULIAR-VILLAMAR, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
On April 20, 1967, Elena Manantan sold a parcel of land to her nine children. By June 6, 1983, several of these children sold their shares to their brother, Simplicio Penuliar, except for Modesta and Felipe. Simplicio later sold his total share to his daughter, petitioner Corazon Penuliar-Villamar, on September 7, 1989. Subsequently, Corazon and her husband, Revelo Villamar, registered a notarized Deed of Sale dated November 23, 1989, with the Office of the Provincial Assessor. This deed falsely indicated that all of Elena’s children, including Modesta and Felipe, sold the property to the spouses. The signatures of Modesta, Hermogenes, and Lucia were forged. The spouses claimed that employees of the Assessor’s Office committed the falsification without their knowledge.
In 1999, Modesta discovered the falsified deed. An Information dated September 7, 2000, charged the spouses with Falsification of Public Document. The Municipal Trial Court in Cities (MTCC) found them guilty beyond reasonable doubt, a decision affirmed by the Regional Trial Court (RTC) and the Court of Appeals (CA). The lower courts rejected the defense of good faith, noting the spouses’ failure to promptly inform Modesta, their possession of the falsified document, and the benefit they derived from it.
ISSUE
Whether the Court of Appeals erred in affirming the petitioners’ conviction for Falsification of Public Document.
RULING
The Supreme Court denied the petition and affirmed the CA decision. The Court emphasized that the petition, filed under Rule 45, raises questions of fact, which are not reviewable. The core issue of whether the petitioners were innocent of the falsification’s existence requires a re-evaluation of evidence, which is a question of fact. Factual findings of the lower courts are final and binding unless they fall under established exceptions, such as grave abuse of discretion or findings grounded on speculation. The petitioners failed to demonstrate that any such exception applied.
The Court upheld the lower courts’ application of the legal presumption that the person who benefits from a falsified public document and is in possession of it is presumed to be the author of the falsification. The petitioners’ defense of good faith, attributing the falsification to unnamed assessor’s office employees, was deemed unsupported by clear and convincing evidence. Their conduct, including their failure to immediately disclose the discrepancy to Modesta and their acceptance of the falsified document, negated their claim of innocence. Thus, the prosecution successfully proved guilt beyond reasonable doubt.