In Belgica v. Belgica, the Supreme Court affirmed that the authenticity of a signature in a legal document, specifically a Special Power of Attorney (SPA), rests on the evaluation of evidence, including expert testimonies and the court’s own examination. The Court upheld the validity of a property sale made under an SPA, despite forgery claims, emphasizing the probative value of original documents and the credibility of notaries public. This decision clarifies the standards for proving forgery and reinforces the importance of presenting original documents in court.

The Forged Signature: How Reliable is Expert Testimony in Challenging a Real Estate Deal?

This case began with a dispute over a house and lot in Quezon City, purchased by Quintin Belgica and his wife, Marilyn. While Quintin was abroad, Marilyn, using a Special Power of Attorney (SPA), sold the property to Antonio Ong. Upon his return, Quintin contested the sale, alleging that his signature on the SPA was forged. He sought an NBI examination, which initially suggested discrepancies between the questioned signature and his standard signatures. However, this preliminary finding was based on a photocopy of the SPA, with the NBI report explicitly stating that “A definite determination may be made, subject to analysis of the original copy of the Special Power of Attorney bearing the questioned signature ‘Quintin B. Belgica.’” This set the stage for a legal battle centered on proving the authenticity of the SPA.

The case proceeded to the Regional Trial Court (RTC), where Quintin filed a complaint to annul the deed of sale. At trial, both parties presented expert witnesses to testify on the signature’s authenticity. The NBI document examiner, who initially examined a photocopy, pointed out differences in the signature’s structural pattern and stroke direction. In contrast, the respondents presented a PNP Crime Laboratory chief, who, after examining a carbon original copy of the SPA, concluded that the signature was genuine. This divergence in findings highlighted the critical role of the type of document examined, with original documents carrying greater weight in forensic analysis.

Adding another layer to the evidence, Atty. Leopoldo Balguma, the notary public who notarized the SPA, testified that Quintin signed the document in his presence. The RTC ultimately sided with the respondents, finding Quintin’s signature on the SPA to be authentic and, consequently, the sale to Antonio Ong valid. Quintin appealed to the Court of Appeals (CA), which affirmed the RTC’s decision, stating that there was an absence of strong evidence to warrant the reversal of the RTC decision. Undeterred, Quintin elevated the case to the Supreme Court, questioning the authenticity of the SPA once again.

The Supreme Court reiterated the principle that appeals by certiorari under Rule 45 of the Rules of Court should generally involve only questions of law. It emphasized that questions of fact, such as the authenticity of a signature, are best resolved by the lower courts. The Court stated: “There exists a question of law when there is doubt on what the law applicable to a certain set of facts is. Questions of fact, on the other hand, arise when there is an issue regarding the truth or falsity of the statement of facts.” In this case, the Court found that the petitioner was asking it to consider a question of fact, which had already been decided upon by the RTC and the CA.

The Supreme Court highlighted the significance of examining original documents in cases involving forgery. The Court noted that the testimony of the petitioner’s expert witness was deemed less conclusive because it was based on a photocopy of the SPA. The Court emphasized that the expert himself admitted that examining a photocopy could affect the result. On the other hand, the testimony of the respondents’ expert witness was found more persuasive because it was based on a carbon original copy of the document. The Court cited Rule 130, Section 4 of the Rules of Court, which defines the original of a document.

Sec. 4. Original of document.

(a) The original of a document is one the contents of which are the subject of inquiry.

(b) When a document is in two or more copies executed at or about the same time, with identical contents, all such copies are equally regarded as originals. xxx

The Supreme Court also emphasized that judges are not solely reliant on expert testimony when determining the authenticity of a signature. The Court underscored that judges can and must use their own judgment, through an independent examination of the questioned signature. The Court cited the case of Alcos v. Intermediate Appellate Court, stating: “It is important to note that the authenticity of a signature though often the subject of proffered expert testimony, is a matter that is not so highly technical as to preclude a judge from examining the signature himself and ruling upon the question of whether the signature on a document is forged or not. It is not as highly technical as questions pertaining to quantum physics, topology or molecular biology.” The Court affirmed that both the RTC and the CA had properly considered the expert testimonies but also based their findings on their own evaluation of the document.

Furthermore, the Supreme Court gave weight to the testimony of the notary public, Atty. Balguma, who stated that the petitioner signed the SPA in his presence. The Court reiterated that the testimony of a notary public enjoys greater credence than that of an ordinary witness. This is because notaries public are officers of the court and their testimonies carry a presumption of regularity. This principle is rooted in jurisprudence, as highlighted in Sales v. CA, where the Court affirmed the reliability of a notary’s testimony over mere denials. The convergence of expert testimony based on an original document and the notary public’s attestation solidified the court’s view on the SPA’s validity.

The Supreme Court’s decision in this case underscores the importance of presenting original documents in court, particularly in cases involving forgery. It also highlights the probative value of a notary public’s testimony and the role of judges in independently examining questioned signatures. The burden of proving forgery lies with the party alleging it, and mere denials are insufficient to overcome the presumption of regularity attached to notarized documents. This ruling provides guidance for future cases involving signature disputes and reinforces the integrity of notarized documents in legal transactions. The case serves as a reminder that allegations of forgery must be supported by substantial evidence, and that courts will carefully consider all available evidence, including expert testimony, original documents, and the testimony of notaries public, in resolving such disputes.

FAQs

What was the key issue in this case?	The key issue was whether the signature of Quintin Belgica on a Special Power of Attorney (SPA) was forged, which would invalidate the sale of his property by his wife. The court needed to determine the authenticity of the signature to decide if the sale was valid.
What evidence did the court consider in determining the authenticity of the signature?	The court considered expert testimonies from both sides, with one expert examining a photocopy and another examining a carbon original. The court also considered the testimony of the notary public who notarized the SPA, and made its own independent examination of the signature.
Why was the expert testimony based on the original document given more weight?	The expert testimony based on the original document was given more weight because it allowed for a more detailed and accurate analysis of the signature’s strokes and nuances. The court acknowledged that examining a photocopy could affect the reliability of the findings.
What is the significance of the notary public’s testimony in this case?	The notary public’s testimony was significant because it provided direct evidence that Quintin Belgica signed the SPA in his presence. The testimony of a notary public carries greater weight than that of an ordinary witness due to their role as officers of the court.
Can a judge make their own determination about the authenticity of a signature?	Yes, a judge can and must use their own judgment, through an independent examination of the questioned signature, in determining the authenticity of the handwriting. This is regardless of expert testimony.
What is the general rule regarding appeals to the Supreme Court?	The general rule is that appeals to the Supreme Court should only involve questions of law, not questions of fact. Questions of fact, such as the authenticity of a signature, are typically resolved by the lower courts.
What is a Special Power of Attorney (SPA)?	A Special Power of Attorney (SPA) is a legal document that authorizes a person (the agent) to act on behalf of another person (the principal) in specific matters. In this case, the SPA authorized Marilyn Belgica to sell the property on behalf of her husband, Quintin.
What is the implication of this ruling for proving forgery in legal cases?	This ruling emphasizes the importance of presenting original documents and credible witnesses, such as notaries public, when alleging forgery. It clarifies that mere denials are insufficient and that the burden of proof lies with the party claiming forgery.

In conclusion, the Supreme Court’s decision in Belgica v. Belgica reinforces the importance of authenticating signatures through meticulous evidence and judicial scrutiny. The case underscores the probative value of original documents and the credibility afforded to notarial attestations in property transactions.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: QUINTIN B. BELGICA VS. MARILYN LEGARDE BELGICA AND ANTONIO G. ONG, G.R. No. 149738, August 28, 2007