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NORA T. JIMENEZ v. COMMISSION ON ECUMENICAL MISSION

FACTS:

The case involves a dispute over a parcel of land originally titled under OCT No. 11757, which was later covered by TCT No. 90689 in the name of United Church of Christ in the Philippines (UCCP). The petitioners are the children of the previous owners, Nicanor Teodoro and Francisca Ciriaco. They filed a complaint in 1982 claiming that their mother was the rightful owner of the property and that the signatures on the Deed of Sale, which transferred ownership to UCCP, were forged. They presented evidence, including testimonies from handwriting experts, to support their claim of forgery. On the other hand, UCCP argued that the property was legally conveyed to them through a valid deed of sale and that the action was already barred by prescription and laches. They presented witnesses and documents to support their position.

The trial court ruled in favor of the petitioners, holding that the signatures on the Deed of Sale were indeed forged. However, the Court of Appeals reversed the decision and upheld the validity of the Deed of Sale and TCT No. 90689. The petitioners then filed a Petition for Review on Certiorari to the Supreme Court, challenging the appellate court's decision.

In 1975, the UCCP filed a petition for reconstitution of the title to the lot, which was granted in 1979. In 1980, the UCCP registered the lot in its name. In 1989, the trial court dismissed the complaint of the petitioners on the grounds of prescription and laches. The Court of Appeals (CA) later reversed the trial court's judgment and remanded the case for further disposition on the unresolved issues. The trial court eventually rendered a judgment declaring the nullity of the deed of sale and the transfer certificate of title (TCT) in favor of the UCCP due to forgery. The trial court also declared the petitioners as the rightful owners of the lot and the respondents as builders in good faith. The CA then reversed the trial court's judgment, finding no substantial indicia of forgery and relying on the validity of the deed of sale. The petitioners raised several issues in their memorandum, challenging the CA's decision.

ISSUES:

  1. Whether the Court of Appeals defied the rule that findings of the trial court are conclusive on the appellate court when it overturned the trial court's finding of forgery.

  2. Whether the Court of Appeals disregarded the rule of preponderance of evidence applicable in civil cases.

  3. Whether the signatures of Francisca Ciriaco and Nicanor Teodoro had been forged.

  4. Whether the findings of the handwriting experts were conclusive and binding on the court.

  5. Whether the signatures on the questioned document can be sighted by a judge and independently judged for authenticity.

  6. Whether the CA disregarded the doctrine of preponderance of evidence.

RULING:

  1. The Petition is not meritorious.

  2. First Issue: No Finding of Forgery

  3. The Court held that the appellate court can intervene and resolve conflicting factual findings of trial courts. In this case, the Court of Appeals had the same opportunity as the trial court in examining and analyzing the questioned signatures. The reliance on the trial court's findings is not applicable when the findings are not anchored on the credibility and testimonies of witnesses, but on the assessment of documents available to appellate magistrates. The Court held that the Court of Appeals did not err in overturning the trial court's finding of forgery. Handwriting experts' opinions are not binding upon courts, and a finding of forgery does not solely depend on the testimony of handwriting experts. The judge must conduct an independent examination of the questioned signature to determine its authenticity. Section 22 of Rule 132 of the Rules of Court provides for this authority of the court to compare the disputed handwriting with writings admitted or proven to be genuine.

  4. The Court of Appeals (CA) concluded that the questioned signatures were not forged after comparing them with the authentic or genuine specimens. The court affirmed the CA's finding, stating that the best evidence of a forged signature is the instrument itself showing the alleged forgeries. The fact of forgery can be established by comparing the allegedly false signature with the authentic or genuine one.

  5. The court held that the findings of the handwriting experts are not conclusive and can be disregarded by the court. It emphasized that the authenticity of signatures is not a highly technical issue and can be determined independently by the judge.

  6. The judge can and should exercise independent judgment on the issue of the authenticity of signatures on a questioned document. In this case, the court examined and analyzed the subject signatures and found no substantial indicia or reason to suspect their authenticity. The differences in the signatures are natural and expected variations in genuine signatures made by the same person. Forgery cannot be presumed and must be proven by clear and convincing evidence.

  7. The CA did not disregard the doctrine of preponderance of evidence. The 1936 Deed of Sale, being a notarized document, carries evidentiary weight. Petitioners did not succeed in challenging the authenticity of the signatures on the notarized Deed. The CA found no reason to doubt their authenticity after having the same opportunity as the RTC to decipher the signatures. The quality, not the number, of witnesses is what matters in determining the weight of evidence. Additionally, the evidence on record supports the CA decision. The fact that petitioners waited until 1982 to file their complaint detracts from their credibility.

PRINCIPLES:

  • Factual findings of the trial court, especially when affirmed by the Court of Appeals, are accorded great weight and respect by the Supreme Court. However, the Supreme Court may intervene and resolve conflicting factual findings of trial courts. The Court's reliance on trial court's findings finds no application when the findings are not anchored on the credibility and testimonies of witnesses, but on the assessment of documents available to appellate magistrates.

  • Handwriting experts' opinions are not binding upon courts, especially when the question involved is handwriting similarity or dissimilarity. The judge must conduct an independent examination of the questioned signature to determine its authenticity. A finding of forgery does not solely depend on the testimony of handwriting experts.

  • Section 22 of Rule 132 of the Rules of Court authorizes the court to compare the disputed handwriting with writings admitted or proven to be genuine.

  • The authenticity of a questioned signature cannot be determined solely based on its general characteristics, similarities, or dissimilarities with the genuine signature. Other factors such as the position of the writer, the condition of the surface, state of mind, and the kind of pen or paper used also play an important role.

  • Forgery cannot be presumed and must be proved by clear, positive, and convincing evidence. The burden of proof lies with the party alleging forgery.

  • The opinion of handwriting experts is not binding on the court, and the judge can make their own independent findings on the matter.

  • The best evidence of a forged signature is the instrument itself showing the alleged forgeries.

  • Signatures on a questioned document can be examined and judged by a judge for authenticity.

  • Forgery cannot be presumed; it must be proven by clear and convincing evidence.

  • The quality, not the number, of witnesses determines the weight of evidence.

  • Notarized documents carry evidentiary weight provided by law.

  • Delay in filing a complaint may detract from a party's credibility.