G.R. No. 142309 - JUAN DELA RAMA AND EUGENIA DELA RAMA, VS. OSCAR PAPA AND AMEUERFINA PAPA. D E C I S I O N - Supreme Court E-Library

Ruling

Accordingly, it held that the cancellation of respondents' title was proper. In addition, the RTC discounted the claim of defendants that laches and estoppel had set in to bar the action, pointing out that under Section 47 of Pres. Decree No. 1529, "no title to registered land in derogation of the title of the registered owner shall be acquired by prescription or adverse possession," and that under Article 1410 of the Civil Code, "[t]he action of defense for the declaration of the inexistence of a contract does not prescribe." [9] Respondents appealed to the Court of Appeals. On 7 September 1999, the appellate court rendered a Decision reversing the RTC and upholding the validity of the deed of sale. [10] The Court of Appeals considered the pivotal issue as whether the signatures of the petitioners on the deed of sale were indeed forged, and ultimately concluded that there was no such evidence to support the finding of forgery. It was observed that the burden of proving the forgery fell upon the petitioners, yet they failed to present convincing evidence to establish the forgery. The only evidence presented to establish the forgery was the oral testimony of Juan dela Rama himself, which according to the Court of Appeals, was self-serving. The RTC was chided for not applying Section 22 of Rule 132 of the Rules of Evidence, which provided in clear terms how handwriting must be proved. It was pointed out that the Rule required that the handwriting of a person be proved "by any witness who believes it to be the handwriting of such person because he has seen the person write, or has seen writing purporting to be his upon which the witness has acted or been charged, and has thus acquired knowledge of the handwriting of such person." [11] Moreover, the Court of Appeals cited that neither one of the dela Ramas was confronted with their signatures in the challenged deed of sale. Nor did they positively and unequivocally declare that the signatures were not theirs or that these were forged. II. Hence, this petition for review. Petitioners devote considerable effort in highlighting facts and admissions elicited from Oscar Papa himself to cast doubt on the validity of the deed of sale. Yet it would be impertinent on our part to immediately dwell on such evidentiary matters without first contending with the legal arguments cited by the Court of Appeals in dismissing the complaint. While this Court is generally not a trier of fact, there are recognized exceptions to that rule, such as when the findings of fact are conflicting, or when the Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties and which, if properly considered, would justify a different conclusion. [12] The petition hinges on a factual question-whether the signatures of the petitioners as appearing on the deed of sale were forged. The Court of Appeals correctly observed that petitioners had the onus probandi to establish such forgery. In concluding that petiti