Reyes v. CA

G.R. No. 110207 (July 11, 1996)

Court denied Reyes' land claim in Makati; ruled Deed of Partition was forged and annulled.

Facts:

On July 29, 1970, a Deed of Extrajudicial Partition and Settlement was allegedly executed between petitioner Florentino Reyes and his sisters, private respondents Jacinta, Paula, and Petra Reyes, concerning a parcel of land in Bangkal, Makati, measuring 383 square meters. This land was registered under the name of their father, Bernardino Reyes. The Deed purportedly stated that the sisters waived their rights and interests in favor of Florentino, with Paula receiving a 50-square meter share.

Florentino registered the Deed with the Register of Deeds of Rizal on March 16, 1971, subsequently obtaining Transfer Certificate of Title No. 318944, which reflected 333 square meters in his name and 50 square meters in Paula's name. However, in May 1985, the private respondents discovered the registration of the Deed and denied having knowledge of its execution, claiming their signatures were forged. They also contended that the notary public, Atty. Jose Villena, was not accredited in Pasay City, where the Deed was purportedly notarized.

Following this, Florentino executed a Deed of Absolute Sale, selling 240 square meters of the land to his children while retaining 93 square meters for himself. The private respondents filed a complaint for annulment of the sale and damages against Florentino and the Register of Deeds of Makati, seeking to nullify the Deed of Extrajudicial Partition, the Deed of Absolute Sale, and several Transfer Certificates of Title.

The Regional Trial Court ruled in favor of the private respondents, finding that the signatures on the Deed were indeed forged. The court permanently enjoined the Register of Deeds from issuing the contested titles to Florentino and his children and declared the Deed and subsequent documents as null and void. The Court of Appeals affirmed this decision.

Legal Issues:

  1. Was the Deed of Extrajudicial Partition and Settlement a forgery?
  2. Assuming forgery, did the petitioners acquire ownership of the land through acquisitive prescription?
  3. Should the complaint be dismissed based on the petitioners' counterclaims?

Arguments:

Petitioners' Arguments:

  • The petitioners contended that the Deed was valid and that the private respondents had not convincingly proven forgery.
  • They argued that even if forgery were established, they had acquired ownership through acquisitive prescription, having possessed the land in good faith for over ten years.
  • They claimed that the trial court erred in not dismissing the complaint and awarding their counterclaims.

Private Respondents' Arguments:

  • The private respondents maintained that they never executed the Deed and that their signatures were forged.
  • They provided evidence that the notary public was not accredited and that the Deed was not recorded properly.
  • They argued that the petitioners could not claim ownership through acquisitive prescription due to the nature of the property being titled and the bad faith involved in the alleged forgery.

Court's Decision and Legal Reasoning:

The Supreme Court dismissed the petition, affirming the findings of the lower courts. The Court held that the factual findings regarding the forgery of the Deed were supported by substantial evidence, including the similarity of signatures and the lack of proper notarization. The Court emphasized that the trial court's findings of fact, which were adopted by the Court of Appeals, are generally conclusive and not subject to review unless specific exceptions apply, none of which were demonstrated by the petitioners.

Regarding the issue of acquisitive prescription, the Court ruled that the petitioners could not claim good faith possession since the basis of their claim was a forged document. The Court reiterated that a forged deed is a nullity and cannot serve as a just title for purposes of acquiring ownership through prescription. Furthermore, the property in question was titled in the name of Bernardino Reyes, and the petitioners could not assert adverse possession against the rightful heirs.

Significant Legal Principles Established:

  • The authenticity of a deed and the validity of signatures are questions of fact, and findings by the trial court are generally conclusive unless specific exceptions are met.
  • A forged document is considered a nullity and cannot confer rights or ownership, negating claims of good faith possession and acquisitive prescription.
  • The requirement of good faith in possession is not met if the claimant is aware of the flaws in their title or mode of acquisition.