G.R. No. 194189. September 14, 2017 (Case Brief / Digest)

Title: **Almeda et al. v. Heirs of Ponciano Almeda et al. (818 Phil. 239)**

Venancio Almeda and Leonila Laurel-Almeda, an elderly couple who were parents to nine children, executed a Power of Attorney in favor of their eldest child, Ponciano L. Almeda, granting him the authority to sell parcels of land inherited by Leonila. This led to the sale of specific lots under two Original Certificates of Title (OCT) to various buyers through deeds of absolute sale facilitated by Ponciano as their attorney-in-fact. After the death of Venancio and Leonila, a notice of adverse claim was filed by five of their children and the husband of their deceased daughter against the registered properties, disputing the validity of the sales orchestrated by Ponciano. They asserted that the deeds of sale were either simulated or the signatures of their parents were forged, claiming no knowledge or receipt of consideration for the sales, and sought to have the sales nullified and the properties partitioned among the heirs.

The regional trial court dismissed their complaint, finding that the contested documents bore the presumption of regularity and the petitioners failed to present sufficient evidence to overcome this presumption. The Court of Appeals upheld this dismissal, emphasizing the petitioners’ inability to prove forgery with clear, convincing evidence and noting the legal presumption of regularity afforded to notarized documents.

1. Whether the Deeds of Absolute Sale were forged or simulated.
2. Whether Venancio and Leonila were competent and voluntarily executed the deeds.
3. Whether the price consideration in the deeds was conscionable and adequately proven.
4. The legal effect of the late registration of the Deeds of Absolute Sale and discrepancies in tax declarations.

**Court’s Decision:**
The Philippine Supreme Court denied the petition, affirming the decisions of the lower courts. Key conclusions include:
– Notarized documents, like the Deeds of Absolute Sale in question, enjoy a presumption of regularity that can only be overturned by clear, convincing evidence of falsity or simulation, which the petitioners failed to provide.
– Allegations of forgery were not substantiated with convincing evidence, as the variance in signatures deemed as forgery was not adequately proven against the standard signatures of Venancio and Leonila.
– The court found no sufficient basis to doubt the mental competence of Venancio and Leonila to execute the sales or evidence of undue influence exerted by Ponciano.
– Concerns over the adequacy of price consideration and the procedural issues surrounding the deeds’ notarization and registration were also dismissed, with the court emphasizing the chronological and juridical consistency in the execution and subsequent transactions involving the properties.

This case reiterates the doctrine that notarized documents have a presumption of regularity and authenticity, placing the burden of proof on the party alleging forgery or falsity to provide clear, convincing evidence to the contrary. Additionally, it underscores the principles regarding the competence to contract, stating that mere advanced age or infirmities are insufficient to prove lack of capacity or voluntariness in executing a contract unless it is proven that such conditions significantly impaired their mental faculties.

**Class Notes:**
1. **Presumption of Regularity:** Notarized documents are presumed regular and authentic until proven otherwise.
2. **Burden of Proof:** The party alleging forgery must prove such claims with clear, convincing evidence.
3. **Competency to Contract:** Advanced age or infirmities alone do not constitute incapacity to contract unless it explicitly impairs mental faculties.
4. **Consideration in Contracts:** The adequacy of consideration and its proof are critical in evaluating the validity of contracts, specifically in cases alleging simulation or forgery.

**Historical Background:**
This legal battle illuminates the procedural and evidentiary challenges faced in contesting the validity of contracts posthumously, particularly when notarized documents are involved. It further highlights the significance of notarization in Philippine legal practice and the reliance on the presumption of regularity and authenticity that such documents carry. This case serves as a jurisprudential reaffirmation of established doctrines regarding contract law, notarization, and the burdens of proof in allegations of forgery and simulation in the context of property disputes among heirs.


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