In Pastor de Jesus v. Court of Appeals, the Supreme Court affirmed the nullification of a Deed of Sale due to a forged signature. The Court emphasized that a document purporting to transfer property rights requires genuine consent from all parties involved, and forgery invalidates such consent. This ruling protects inheritance rights, ensuring that rightful heirs are not deprived of their due share based on fraudulent documents.

Can a Forged Signature Nullify a Property Sale? The Case of the Disputed Inheritance

The case revolves around a parcel of land inherited by Juan and Eustaquia de Jesus, and subsequently passed on to their children, Fermin, Consolacion, and Pastor de Jesus. After Fermin’s death, his children (the respondents) sought to partition the land. However, Pastor de Jesus claimed that Fermin had already sold his share to him via a Deed of Sale. The respondents contested the validity of this deed, alleging that Fermin’s signature was forged.

The Regional Trial Court (RTC) ruled in favor of the respondents, declaring the Deed of Sale null and void and ordering the partition of the property. The Court of Appeals (CA) affirmed this decision, but modified it to declare the deed void only with respect to Fermin’s share. Pastor de Jesus then elevated the case to the Supreme Court, arguing that the lower courts erred in giving more weight to the opinion of a handwriting expert than to the testimonies of witnesses who attested to the authenticity of Fermin’s signature. Building on this, he claimed the presumption of regularity for notarized documents was not sufficiently rebutted.

At the heart of the matter was the authenticity of Fermin’s signature on the Deed of Sale. The respondents presented handwriting expert Zenaida Torres, who testified that the signature on the deed did not match Fermin’s standard signatures. Further, the RTC and CA conducted their own independent examinations of the signatures and observed noticeable disparities. This evidence contrasted with the testimonies of Pastor de Jesus and his witnesses, who claimed that Fermin had indeed signed the document in their presence. However, the courts found these testimonies inconsistent and lacking credibility.

The Supreme Court, in its decision, underscored that under Rule 45 of the 1997 Rules of Civil Procedure, it primarily addresses questions of law, rather than re-evaluating factual findings already established by lower courts. The Court reiterated that findings of fact by the Court of Appeals, particularly when affirming those of the trial court, are generally conclusive, especially if supported by substantial evidence.

The Court acknowledged the presumption of regularity afforded to notarized documents. However, it emphasized that this presumption is not absolute and can be overturned by clear and convincing evidence of forgery or fraud. In this case, the Court found that the evidence presented by the respondents, including the expert testimony and the courts’ own examination of the signatures, was sufficient to rebut the presumption of regularity. It ruled that due to the forged signatures, the entire Deed of Sale was nullified because it was essentially an extrajudicial settlement which requires the consent of all the heirs:

It is not binding upon any person who has not participated therein or had notice thereof.

Therefore, the Supreme Court denied Pastor de Jesus’s petition, affirming the RTC’s original decision and reinstating it in full. The Court emphasized the importance of protecting the inheritance rights of legitimate heirs and preventing the fraudulent transfer of property.

FAQs

What was the key issue in this case?	The primary issue was whether the Deed of Sale, presented as evidence of Fermin de Jesus’s consent to transfer his share of inherited property, was valid despite allegations of a forged signature. The courts had to determine if the evidence presented sufficiently proved that the signature was indeed a forgery, thereby nullifying the document.
What is an extrajudicial settlement and why is it relevant?	An extrajudicial settlement is an agreement among heirs to divide an estate without going to court. This case hinged on whether all the heirs, including Fermin de Jesus (through a valid signature), consented to the sale.
Why was the testimony of the handwriting expert important?	The handwriting expert’s testimony provided technical analysis comparing the disputed signature with known genuine signatures of Fermin. While not the only factor, it was a key piece of evidence supporting the claim of forgery.
What is the “presumption of regularity” for notarized documents?	A notarized document is generally presumed to be authentic and duly executed. However, this presumption can be overturned if there’s strong evidence of fraud or forgery.
How did the courts determine that the signature was forged?	The courts relied on the expert’s analysis, their own visual comparison of the signatures, and inconsistencies in the testimonies of witnesses supporting the document’s authenticity. These factors, taken together, convinced the courts that the signature was not genuine.
What happens when a signature on a Deed of Sale is proven to be forged?	If a signature on a Deed of Sale is proven to be forged, the document is considered invalid and unenforceable, and the transaction is nullified, meaning it’s treated as if it never happened. The consent of all parties to the sale is necessary to the validity of the transfer.
Can family members testify about the authenticity of a signature?	Yes, family members who are familiar with a person’s handwriting can provide testimony. However, the court weighs such testimony alongside other evidence, like expert opinions and its own analysis.
What was the final outcome of the case?	The Supreme Court upheld the lower courts’ decision, declaring the Deed of Sale null and void in its entirety. This secured the inheritance rights of Fermin de Jesus’s children (the respondents) to their rightful share of the land.

This case underscores the importance of verifying the authenticity of signatures on legal documents, especially those concerning property rights. The Supreme Court’s decision reaffirms the principle that a forged signature invalidates consent, thereby protecting the inheritance rights of legitimate heirs. It serves as a crucial reminder that fraudulent documents will not be upheld, and rightful ownership will prevail.

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: Pastor De Jesus v. Court of Appeals, G.R. No. 127857, June 20, 2006