GR 209264; (July, 2016) (Digest)
G.R. No. 209264 , July 5, 2016
DAMASO T. AMBRAY and CEFERINO T. AMBRAY, JR., Petitioners, vs. SYLVIA A. TSOUROUS, et al., Respondents.
FACTS
The case involves a parcel of land, Lot 2-C, originally part of the conjugal property of the late spouses Ceferino Ambray, Sr. and Estela Trias. Petitioners Damaso and Ceferino Jr., sons of the spouses, obtained Transfer Certificate of Title (TCT) No. T-41382 for Lot 2-C based on a Deed of Absolute Sale dated January 16, 1978, purportedly executed in their favor by their parents. Their siblings, the respondents, discovered the title in 1996 and filed a criminal case for falsification of public document against the petitioners, alleging the signatures on the deed were forged. The petitioners were acquitted in the criminal case due to the prosecution’s failure to prove guilt beyond reasonable doubt.
Subsequently, the respondents filed a civil complaint for annulment of title, reconveyance, and damages. The petitioners moved to dismiss, arguing the civil action was barred by res judicata due to the prior acquittal. The Regional Trial Court (RTC) initially dismissed the case but was reversed on appeal by the Court of Appeals (CA), which remanded the case for trial. After proceedings, the RTC ruled in favor of the respondents, declaring the deed and title null and void and ordering reconveyance. The CA affirmed this decision.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s decision which declared the Deed of Absolute Sale null and void and ordered the reconveyance of the subject property.
RULING
The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the civil action for annulment of title and reconveyance was not barred by the petitioners’ acquittal in the criminal case for falsification. The acquittal was based on failure to prove guilt beyond reasonable doubt, a standard distinct from the preponderance of evidence required in civil cases. Thus, res judicata did not apply.
On the merits, the Court found the respondents successfully proved by preponderance of evidence that the Deed of Absolute Sale was spurious. The RTC and CA correctly gave weight to the testimony of a handwriting expert who concluded that the signatures of Ceferino Sr. and Estela on the deed were forgeries when compared to their standard signatures. The petitioners failed to present credible evidence to rebut this finding. The deed’s suspicious circumstances, including its execution date preceding the subdivision of the parent lot and its registration only in 1996, long after the alleged sale, further supported its invalidity.
Consequently, the conveyance was void. Lot 2-C remained part of the conjugal estate of Ceferino Sr. and Estela, to be inherited by all their heirs. The petitioners, having registered the void deed, held the title in trust for the benefit of all co-heirs. The Court upheld the orders for the annulment of the deed and title, and the reconveyance of the property to the co-ownership of the heirs for proper partition.