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NORMA DELOS REYES VDA. DEL PRADO v. PEOPLE

FACTS:

Norma Delos Reyes Vda. Del Prado, Normita Del Prado, Eulogia Del Prado, and Rodelia Del Prado were charged with falsification of a Deed of Succession, claiming ownership of a parcel of land to the exclusion of Ma. Corazon Del Prado-Lim who was also an heir. The prosecution presented evidence that Corazon was the daughter of Rafael Del Prado and her rights over the land were agreed upon in legal documents, but were not registered. The petitioners denied signing the deed and appearing before the notary public. They were found guilty beyond reasonable doubt by the Municipal Trial Court (MTC) and were sentenced to an indeterminate penalty. The Regional Trial Court (RTC) affirmed the MTC's decision with modification, dismissing the case against Rodelia due to her minority at the time of the offense. The Court of Appeals (CA) affirmed the RTC's ruling, but modified the imposable penalty. The petitioners' motion for reconsideration was denied by the CA.

ISSUES:

  1. Whether the Court of Appeals erred in affirming the petitioners' conviction for falsification, despite their defense that they never intended to exclude private complainant Corazon from the estate of the late Rafael.

  2. Whether the questions being raised by the petitioners refer to factual matters that are not proper subjects of a petition for review under Rule 45 of the Rules of Court.

  3. Whether or not the petitioners acted in good faith in making a false statement in the deed of succession.

  4. Whether or not the deed of succession caused prejudice and injury to Corazon and third parties.

RULING:

  1. The petition is bound to fail. Only questions of law may be raised in petitions for review on certiorari under Rule 45 of the Rules of Court. The questions being raised by the petitioners refer to factual matters that are not proper subjects of a petition for review under Rule 45. It is not the function of the Supreme Court to analyze or weigh evidence already considered by the lower court, as our jurisdiction is limited to reviewing errors of law committed by the lower court. The resolution of factual issues is within the function of the lower courts, whose findings on these matters are received with respect. Therefore, the Court of Appeals did not err in affirming the petitioners' conviction for falsification.

  2. The petitioners did not act in good faith in making a false statement in the deed of succession. Their prior confirmation and recognition of Corazon's right as an heir, despite their knowledge of said fact, contradict their claim of good faith.

  3. The deed of succession caused prejudice and injury to Corazon and third parties. The false statement made in the deed affected the indefeasibility of titles and deprived Corazon of her right as a landowner, to the clear prejudice of third persons who would rely on the land titles issued based on the deed.

PRINCIPLES:

  • Only questions of law may be raised in petitions for review on certiorari under Rule 45 of the Rules of Court.

  • The resolution of factual issues is within the function of the lower courts, and their findings on these matters are received with respect.

  • The Supreme Court's jurisdiction is limited to reviewing errors of law committed by the lower court.

  • The recognized exceptions to the rule on questions of law as subjects of petitions for review are: (1) when the findings are grounded entirely on speculation, surmises or conjectures, (2) when the inference made is manifestly mistaken, absurd or impossible, (3) when there is grave abuse of discretion, (4) when the judgment is based on misapprehension of facts, (5) when the findings of fact are conflicting, (6) when in making its findings, the CA went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee, (7) when the CA's findings are contrary to those by the trial court, (8) when the findings are conclusions without citation of specific evidence on which they are based, (9) when the acts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondent, (10) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record, or (11) when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.

  • The elements of the crime of falsification under Art. 171, par. 4 of the Revised Penal Code, in relation to Art. 172 thereof, are: (a) The offender makes in a public document untruthful statements in a narration of facts; (b) The offender has a legal obligation to disclose the truth of the facts narrated by him; and (c) The facts narrated by the offender are absolutely false.

  • Good faith is a requirement to protect the indefeasibility of titles under land registration.

  • False statements in deeds that affect the indefeasibility of titles can cause prejudice and injury to the rightful owners and third parties.