G.R. No. 191936. June 01, 2016
VIRGINIA D. CALIMAG, PETITIONER, VS. HEIRS OF SILVESTRA N. MACAPAZ, REPRESENTED BY ANASTACIO P. MACAPAZ, JR., RESPONDENTS.

FACTS

Virginia Calimag and Silvestra Macapaz were co-owners of a property in Makati. Upon Silvestra’s death in 2002, Calimag secured a new Transfer Certificate of Title (TCT) in her name alone in 2005, based on a Deed of Sale dated January 18, 2005, which purported to show that Silvestra had sold her share to Calimag. The respondents, Anastacio Macapaz, Jr. and Alicia Macapaz-Ritua, claiming to be the legitimate children of Silvestra’s brother Anastacio Macapaz, Sr. and thus Silvestra’s intestate heirs, filed an action for annulment of the deed and cancellation of the new title. They alleged the deed was a forgery, as Silvestra had died years before its purported execution. Calimag countered that the respondents lacked legal capacity to sue, asserting they were illegitimate children and, under Article 992 of the Civil Code, could not inherit from Silvestra, a legitimate relative of their father.
The Regional Trial Court (RTC) ruled in favor of the respondents, declaring the deed void due to forgery and ordering the cancellation of Calimag’s title. The RTC found the respondents had successfully proven their legitimate filiation. The Court of Appeals (CA) affirmed the RTC’s decision, modifying only the damages awarded. Calimag elevated the case to the Supreme Court, primarily contesting the respondents’ legal standing as legitimate heirs.

ISSUE

Whether the respondents have the legal capacity to institute the action for annulment of the deed of sale and cancellation of title as the legitimate heirs of Silvestra Macapaz.

RULING

Yes, the respondents have the legal capacity to sue. The Supreme Court affirmed the CA and RTC rulings. The core legal logic rests on the presumption of validity of marriage and the consequent presumption of legitimacy of children. The petitioner’s challenge to the respondents’ status was based on a negative certification from the National Statistics Office (NSO) stating it had no record of the marriage between Anastacio Macapaz, Sr. and Fidela Poblete. The Court held that such a negative certificate is not conclusive proof of the non-existence of a marriage. It merely indicates the absence of a record in that particular office, not that the event did not occur. The law presumes a man and a woman conducting themselves as husband and wife are legally married, and children born during such a union are presumed legitimate.
The respondents presented competent evidence to support their legitimacy, including their birth certificates naming Anastacio Macapaz, Sr. and Fidela as their parents, with Fidela signing as “Fidela P. Macapaz.” They also submitted a canonical marriage certificate. This evidence sufficiently established their filiation. Since the petitioner failed to present clear, strong, and convincing evidence to rebut the presumptions of marriage and legitimacy, the respondents’ status as legitimate children of Silvestra’s brother stands. As such, they are legal heirs of the deceased Silvestra Macapaz and possess the requisite legal interest and personality to challenge the fraudulent deed that deprived their inheritance. The finding of forgery of the deed, which was executed years after the purported vendor’s death, was thus properly upheld, justifying the annulment and cancellation of the derived title.