Case Digest: ALORIA v. CLEMENTE

MANUEL B. ALORIA v. ESTRELLITA B. CLEMENTE
483 SCRA 634 (2006)

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

Manuel Aloria learned that Transfer Certificate of Title (TCT) No. 195684 covering his land and two-storey residential building was canceled. In lieu thereof, TCT No. C-342854 was issued in the name of Estrellita B. Clemente on the basis of a notarized Deed of Absolute Sale allegedly executed by him and Clemente. Aloria thereafter filed a Complaint against Clemente and the Register of Deeds before the Regional Trial Court (RTC) of Caloocan City for annulment of the Deed and TCT No. C-342854, reconveyance and damages alleging therein that the Deed was falsified and the signature appearing thereon was not his.
In defense, Clemente claimed that she bought the property from Aloria‘s parents-in-law as evidenced by a Deed of Sale. The trial court rendered its decision holding that the Deed of Sale and cancellation of Aloria‘s title were null and void. On appeal, the Court of Appeals reversed the decision of the trial court. It held that Aloria failed to overcome by clear, strong, and convincing evidence the presumption of regularity. Furthermore, the CA held that Clemente is a purchaser for value in good faith. Hence, this petition.

ISSUES:

Whether or not the Court of Appeals erred in finding Clemente as a purchaser for value and in good faith.

HELD:

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

By Clemente‘s account, she purchased the property via Deed of Sale from the Spouses Diego whom she claims showed her a Deed of Sale executed in their favor by Aloria. Given Bernardino Diego‘s denial that his signature in Deed of Sale executed by the Diegos in Clemente‘s favor is his which, as earlier observed, is starkly different from his acknowledged genuine signature, Clemente‘s claim that Bernardino Diego signed the Deed of Sale in her presence fails, as does her witness Ernesto Tanigue‘s testimony on the same point.

A comparison between her acknowledged signature and the signature appearing above her name in the Deed of Sale reveals no marked differences. The presumption that Clemente’s signature in the Deed of Sale is genuine, thus stands. Upon the other hand, as reflected above, Aloria presented clear and convincing evidence that the signature attributed to him in the same document is forged.