Rogelia R. Gatan and the Heirs of Bernardino Gatan, namely Rozalino Gatan and Ferdinand Gatan v. Jesusa Vinarao and Spouses Mildred Cabauatan and Nomar Cabauatan - G.R. No. 205912 - October 18, 2017

Facts:

Petitioner Rogelia and her husband, the late Bernardino Gatan, acquired a parcel of land surveyed in the latter’s name in October 1964. Sometime in January 2002, respondent spouses Cabauatan asked Rogelia if they could temporarily erect a house on spouses Gatan’s property. Rogelia agreed since respondent Mildred was her late husband’s relative.

More than four years later, Rogelia learned of a certain Deed of Absolute Sale supposedly executed by her late husband in December 1989 conveying a portion of their property in favor of respondent Mildred’s parents for a consideration of PHP 4,000. Due to this, Rogelia confronted spouses Vinarao regarding the falsified Deed of Absolute Sale and demanded respondent spouses Cabauatan to vacate subject property. Petitioners then filed before the Regional Trial Court a complaint for Nullity of Document and Recovery of Possession with Damages against respondents.

The Regional Trial Court denied their petition while the Court of Appeals affirmed the lower court’s ruling.

Issue:

Whether or not the Court of Appeals erred in affirming the trial court’s decision in upholding the validity of the subject deed of sale

Ruling:

The petition was denied.

Whether or not the signatures of Bernardino and petitioner Rogelia appearing on the Deed of Absolute Sale are forgeries is a question of fact which is beyond the Court’s jurisdiction under the present Petition for Review on Certiorari.

The jurisdiction of the Court under Rule 45, Sec. 1 of the Rules of Court is limited only to errors of law as the Court is not a trier of facts. None of the recognized exceptions, which allow the Court to review factual issues, exists in this case.

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