Facts:
The case originated from a Complaint for Declaration of Nullity of Conveyance and Recovery of Possession and Damages filed on May 12, 1990, by Luzviminda C. Dimaun against Dionisio C. Ladignon, Richard C. Tong, Jose Porciuncula Jr., and Litogo Company, Inc. Luzviminda claimed that Ladignon offered to mediate between her and her adoptive mother’s relatives concerning an inheritance matter. During this process, Luzviminda allegedly signed a Petition for reconstitution of Transfer Certificate of Title No. 240724 for a property in Quezon City, registered under her and her adoptive mother’s names.
The Petition was dismissed for Luzviminda’s failure to attend a hearing, a fact she was allegedly unaware of. She also claimed ignorance about the issuance of a new TCT (No. 383675) under her name. Attached to Luzviminda’s complaint was a Deed of Absolute Sale showing a sale of the property to Litoco Co., Inc. for P800,000, a document she claims to have neither signed nor received payment for, alleging falsified signatures.
During pre-trial, the issues were focused on the authenticity of Luzviminda’s signature in the deed, the effect of the non-reconstitution of TCT No. 240724, and defendants’ liability for damages. The RTC ruled in favor of Ladignon, dismissing the complaint and awarding damages and attorney’s fees to him. Luzviminda appealed, and the Court of Appeals reversed the RTC decision, questioning the authenticity of TCT No. 383675 and the legitimacy of the deed’s execution.
Issues:
1. Whether the signatures on the Deed of Absolute Sale were forged.
2. Whether the lack of reconstitution affects the issuance of TCT No. 383675.
3. Whether defendants should be liable for damages regarding deprivation of Luzviminda’s inherited property.
4. Whether the Court of Appeals erred in reversing the RTC’s factual findings and for alleged abuses of discretion.
Court’s Decision:
The Supreme Court focused on the presumption of regularity and validity of notarized public documents like the Deed of Absolute Sale. It held that Luzviminda failed to present clear, convincing evidence to overcome this presumption or to prove forgery. Her mere denial of signing the document was insufficient. Additionally, a comparison of signatures by an expert was lacking, failing to meet the burden of proof for forgery.
Regarding TCT No. 383675, the Court noted that the Court of Appeals improperly focused on its validity since its cancellation required a direct proceeding rather than a collateral attack in this nullity of conveyance action.
Doctrine:
The decision reinforced the presumption of regularity attached to notarized documents and stressed the need for clear, convincing, and preponderant evidence to overcome this presumption. It reiterated that forgery must be proven with clear and positive evidence, and burdens of proof rest on the party alleging forgery. Also, the validity of torrens titles cannot be collaterally attacked.
Class Notes:
– Presumption of Regularity: Notarized documents hold a strong presumption of validity and regularity unless convincingly contradicted.
– Forgery: Forgery must be proven by clear and convincing evidence; mere denial or perceived variances in signatures are insufficient.
– Attack on Torrens Title: A Torrens Title’s validity can only be challenged through a direct proceeding, not collaterally.
Historical Background:
This case reflects the judicial emphasis on the integrity of notarized documents and the legal protective measures inherent in the Torrens system, underscoring procedural necessities for challenging land and property documents in the Philippines. It adds layers of protection against unwarranted claims of forgery, ensuring transactions’ stability, which has been crucial in land title jurisprudence in the Philippines.
Leave a Reply