The Supreme Court’s decision in Spouses Asuncion Malig-Coronel v. Corazon Solis-Quesada clarifies the burden of proof in land disputes involving allegations of forgery and the rights of innocent purchasers for value. The Court ruled that the Spouses Coronel failed to provide clear and convincing evidence of forgery in the deeds transferring ownership, and thus, their claim for reconveyance was denied. This ruling underscores the importance of presenting concrete evidence to challenge the validity of notarized documents and protects the rights of those who acquire property in good faith.

Unraveling a Land Dispute: Did Forged Signatures Cloud a Property Title?

The case revolves around a parcel of land originally owned by the Spouses Asuncion and Reynaldo Coronel. They entrusted the property’s care to Asuncion’s aunt, Catalina Hernando. Subsequently, a series of transactions occurred, beginning with a Deed of Donation allegedly transferring the property to Catalina’s granddaughter, Mina Delos Reyes. Delos Reyes then sold the property to Corazon Solis-Quesada. The Spouses Coronel contested these transfers, claiming that the Deed of Donation and the subsequent Deed of Absolute Sale were forgeries. They filed a complaint seeking annulment of the deeds, cancellation of the title, and reconveyance of the property. Quesada, on the other hand, asserted her right as a purchaser in good faith and for value.

The Regional Trial Court (RTC) granted Quesada’s demurrer to evidence, finding that the Spouses Coronel failed to sufficiently prove their claims. The Court of Appeals (CA) affirmed the RTC’s decision. The central issue before the Supreme Court was whether the Spouses Coronel presented sufficient evidence to warrant the reconveyance of the subject property, considering their allegations of forgery and their claim that Quesada was not an innocent purchaser.

The Supreme Court began its analysis by reiterating the nature of an action for reconveyance. An action for reconveyance is a legal remedy available to a rightful owner of land that has been wrongfully registered in another person’s name. It aims to transfer the property to its rightful owner. This remedy is often invoked when fraud or error taints the registration process. The Court emphasized that while the decree of registration is respected, the action seeks to correct the wrongful transfer of ownership.

The Court then addressed the applicable legal framework. Section 53 of Presidential Decree No. 1529, the Land Registration Act, allows an owner to pursue legal and equitable remedies against parties involved in fraudulent registration, provided it does not prejudice the rights of an innocent holder for value. This is further connected to Article 1456 of the Civil Code, which establishes an implied trust when property is acquired through mistake or fraud, obligating the recipient to act as a trustee for the benefit of the person from whom the property came. Together, these provisions provide the basis for actions seeking reconveyance.

The prescriptive period for such actions is generally ten years from the issuance of the certificate of title, as provided by Article 1144(2) of the Civil Code. However, this prescriptive period does not apply to a party in actual, continuous, and peaceful possession of the property, as their action is considered a suit for quieting of title, which is imprescriptible. An action for reconveyance based on a void contract, such as one lacking consent, is also imprescriptible. This principle acknowledges that void contracts cannot give rise to valid rights, and therefore, the right to challenge them persists indefinitely. The critical question, therefore, becomes the nature of the underlying claim: is it based on implied trust or a void contract?

In this case, the Spouses Coronel argued that their action was based on void contracts due to forgery, specifically in the Deed of Donation and Deed of Absolute Sale. This placed the burden on them to prove the alleged forgery. The Court emphasized that forgery is not presumed; it must be proven by clear, positive, and convincing evidence. The Spouses Coronel primarily relied on Asuncion’s testimony, asserting that the signatures on the deeds were not genuine. However, the Court found this insufficient.

The Court cited Cesar v. Sandiganbayan to emphasize the importance of examining both the differences and similarities in questioned signatures. This examination helps determine whether variations are due to forgery or natural variations in a person’s genuine writing. The Spouses Coronel failed to present expert testimony or provide sufficient signature samples for comparison. The Court noted a significant time disparity between the signatures on the questioned deeds (1995 and 2000) and the signatures offered for comparison (2011 and 2013). This temporal gap made it difficult to draw accurate conclusions about the authenticity of the signatures. As the Court stated in Reyes v. Vidal, the closeness in time between the standard signatures and the questioned signatures is critical for an accurate analysis.

The Court also addressed the Spouses Coronel’s argument that the questioned documents should not be considered public documents due to non-compliance with legal formalities. The Supreme Court emphasized that a notarized document carries a presumption of regularity. To overcome this presumption, clear and convincing evidence is needed. The Spouses Coronel raised this issue only in their motion for reconsideration before the CA, which is procedurally improper. The Court highlighted that issues not raised in the trial court cannot be raised for the first time on appeal, violating the principles of fair play and due process. As such, the Court found no basis to disregard the presumption of regularity attached to the notarized documents.

Finally, the Court considered whether Quesada qualified as an innocent purchaser for value. This status protects individuals who buy property without notice of any defect in the seller’s title. The burden of proving good faith rests on the purchaser. The Spouses Coronel argued that Quesada’s close relationship with Delos Reyes should have alerted her to potential issues with the title. However, the Court found no concrete evidence to support this claim. Every person dealing with registered land may generally rely on the correctness of the certificate of title. While this rule does not apply when a party has actual knowledge of defects or circumstances that should prompt inquiry, the Spouses Coronel failed to demonstrate that Quesada had such knowledge. The court thus ruled in favor of Quesada by stating that:

The burden of proving the status of a purchaser in good faith lies upon one who asserts that status, and this onus probandi cannot be discharged by mere invocation of the legal presumption of good faith.

FAQs

What was the key issue in this case?	The key issue was whether the Spouses Coronel provided sufficient evidence to prove forgery and invalidate the transfer of land ownership to Corazon Solis-Quesada. The court assessed the validity of the documents and the status of Quesada as an innocent purchaser for value.
What is an action for reconveyance?	An action for reconveyance is a legal remedy to transfer land wrongfully registered in another person’s name to its rightful owner. It is often based on fraud or error in the registration process, aiming to correct the wrongful transfer of ownership.
What is the prescriptive period for an action for reconveyance based on fraud?	Generally, the prescriptive period is ten years from the issuance of the certificate of title. However, this does not apply to a party in actual possession or when the action is based on a void contract.
What is required to prove forgery in a legal document?	Forgery must be proven by clear, positive, and convincing evidence. This often requires expert testimony or a comparison of signatures made at a similar time to the questioned document.
What is the significance of a notarized document?	A notarized document is considered a public document and enjoys a presumption of regularity. This means it is presumed to be valid and duly executed unless proven otherwise by clear and convincing evidence.
What is an innocent purchaser for value?	An innocent purchaser for value is someone who buys property without notice of any defect in the seller’s title and pays a fair price. They are protected under the law, even if the seller’s title is later found to be defective.
What is the burden of proof for claiming to be an innocent purchaser?	The burden of proof lies on the person claiming to be an innocent purchaser to demonstrate they bought the property in good faith and without knowledge of any adverse claims. Mere invocation of good faith is not enough.
Why was the timing of signature samples important in this case?	The timing was crucial because the court emphasized that signature samples used for comparison should be from a period close to when the questioned document was signed. This ensures a more accurate analysis, considering that signatures can change over time due to age or health.

In conclusion, the Supreme Court’s decision reinforces the importance of providing concrete evidence when challenging the validity of notarized documents and claiming ownership of land. It protects the rights of innocent purchasers who rely on the correctness of certificates of title. The case serves as a reminder to meticulously gather and present evidence, particularly in cases involving allegations of forgery.

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: Spouses Asuncion Malig-Coronel and Reynaldo Coronel vs. Corazon Solis-Quesada, G.R. No. 237465, October 07, 2019