G.R. No. 181956; November 11, 2010
VICTORIA L. TEH, Petitioner, vs. NATIVIDAD TEH TAN, TEH KI TIAT, and JACINTA SIA, Respondents.

FACTS

Spouses Teh Lin and Lim Ay Go owned a parcel of land. In 1971, they separately executed Deeds of Donation in favor of four of their children: Natividad, Teh Ki Huat, Teh Ki Tiat, and Victoria. After their parents’ deaths, Victoria secured a new title solely in her name in 1994, allegedly based on a separate Deed of Donation dated March 20, 1971, in her favor alone. The other donees filed a complaint, alleging the March 1971 deed was a forgery, as their mother was illiterate and the signatures were spurious. They sought annulment of Victoria’s title and recognition of the earlier, joint donations.
Victoria contested the action, arguing the respondents were not legitimate heirs and that, even if valid, the joint donations were void as the other donees were allegedly not Filipino citizens. She also claimed acquisitive prescription. The Regional Trial Court (RTC) found the March 1971 Deed of Donation in favor of Victoria null and void due to forgery, upheld the validity of the 1971 joint donations, and ordered the cancellation of Victoria’s title and the reinstatement of the original one. The Court of Appeals affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s decision which declared the March 20, 1971 Deed of Donation null and void and upheld the earlier joint donations.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ rulings. The core legal logic rests on the conclusive finding of forgery, which is a question of fact. The RTC’s determination, affirmed by the CA, that the March 1971 deed was spurious is binding in a Rule 45 petition, as the Court does not re-evaluate factual evidence. The RTC based its finding on the credible and uncontradicted testimony of a handwriting expert who concluded the signatures of Teh Lin were forged and that parts of the document were typed on different machines. Victoria failed to present clear and convincing evidence to overturn this factual conclusion.
Consequently, the forged deed transferred no rights to Victoria. The valid and operative instruments were the earlier joint donations from each parent. The Court rejected Victoria’s alternative defenses. The claim of the other donees’ alienage does not invalidate the donations inter vivos from their Filipino parents; such a constitutional restriction applies only to transfers of private agricultural land. Her claim of acquisitive prescription also fails, as possession under a void title does not confer ownership. The reinstatement of the original title was proper to reflect the true state of ownership based on the valid joint donations.