SPS. ROMULO v. CA

## FACTS:

The case involves the revocation of a donation made by Pedro Calapine to his niece, Helen Doria, and the subsequent sale of the donated property to the spouses Romulo and Sally Eduarte. Pedro Calapine executed two deeds of donation in favor of Helen Doria, one ceding half of the land and another ceding the whole parcel of land. Helen Doria then donated a portion of the land to the Calauan Christian Reformed Church, Inc. She later sold the remaining portion to the Eduartes. Pedro Calapine brought a lawsuit to revoke the donation and declare the subsequent deeds of donation and sale as null and void. He alleged that the signature in the second deed of donation was a forgery. After Pedro Calapine's death, his nephews Alexander and Artemis Calapine were substituted as plaintiffs. The trial court rendered a decision in favor of the plaintiffs, and the Court of Appeals affirmed the decision. The petitioners, the spouses Eduarte, appealed the decision, arguing that the offense imputed to Helen Doria, falsification of a public document, is not a ground for revocation under Article 765 of the Civil Code. They also claimed that they were buyers in good faith.

## ISSUES:

  1. Whether the forgery of the donor's signature in the deed of donation and acts of ingratitude constitute valid grounds for the revocation of the donation.

  2. Whether the Court of Appeals erred in ruling that the petitioners (spouses Eduarte) were buyers in bad faith.

  3. Whether the established doctrine that a forged deed can legally be the root of a valid title should apply, protecting the rights of an innocent purchaser for value.

## RULING:

  1. The Supreme Court held that the forgery of the donor’s signature and the acts of ingratitude by the donee Helen Doria are valid grounds for the revocation of the donation. This aligns with Article 765 of the Civil Code and the commentary stating that "all crimes which offend the donor show ingratitude and are causes for revocation."

  2. The High Court overturned the finding of the Court of Appeals that the Eduarte spouses were buyers in bad faith. The Supreme Court found that the petitioners were innocent purchasers for value. They relied on the face of the title, which indicated no defects, and were unaware of any fraudulence in securing the title by the previous owner.

  3. The Supreme Court concluded that relying on a certificate of title that appeared valid on its face is permissible, and the petitioners should not be prejudiced by the fraudulent acts of the previous title holder. The correct recourse for the true owner, who was fraudulently dispossessed, is to seek damages.

## PRINCIPLES:

  1. Forgery and Ingratitude as Grounds for Revocation: A donation can be revoked if the donee commits acts that show ingratitude, including crimes that offend the donor, based on Article 765 of the Civil Code.

  2. Buyers in Good Faith: Purchasers of property who rely on a clean title and have no reason to suspect any irregularity are considered buyers in good faith and their rights must be protected, regardless of previous fraud in securing the title.

  3. Validity of Title Rooted in Forgery Under Certain Circumstances: A forged or fraudulent deed can become the root of a valid title if the land is subsequently sold to an innocent purchaser, thereby supporting the principle that one can rely on what appears on the certificate of title, under the Torrens system of land registration.

  4. Damages for Fraudulent Dispossession: The correct remedy for an original owner who loses property through forgery or fraud is to seek damages from those responsible, and not to impinge upon the rights of innocent purchasers.