FACTS:

Catalina Sanchez filed a complaint for the annulment of a deed of sale, alleging that her late husband, Roberto Sanchez, had fraudulently transferred their property to the petitioners without her knowledge. She presented a handwriting expert report from the Philippine Constabulary Criminal Investigation Service, which found that the signature on the deed of sale was forged. In their answer, the petitioners questioned Catalina's personality to file the complaint, claiming that Roberto Sanchez was never married and had a common-law wife with whom he had two children. The trial court dismissed the complaint, but it was reversed by the Court of Appeals, which found that the signature was indeed forged. The petitioners appealed to the Supreme Court, arguing that the trial court's decision should be reinstated.

ISSUES:

1. Whether the deed of sale was spurious or not.

2. Whether the action to annul the deed of sale had already prescribed.

3. Whether Catalina Sanchez has the capacity to institute the complaint.

RULING:

1. The Court of Appeals held that the trial court erred in ruling that the deed of sale was not spurious. It found that the signature on the document had indeed been forged based on the testimonies of expert witnesses.

2. The Court of Appeals also ruled that the action to annul the deed of sale had not yet prescribed.

3. The Court of Appeals concluded that Catalina Sanchez, as the widow of Roberto Sanchez, had the capacity to institute the complaint.

PRINCIPLES:

• The burden of proof lies with the party making an assertion or seeking relief.

• The mere fact that a person has children out of wedlock does not necessarily preclude him from marrying another person.

• The submission of a marriage contract is sufficient proof to establish marital status.

• The court gives deference to the factual findings of the trial court unless there is a clear showing of error.