Manuel B. Aloria (Represented By His Attorney-In-Fact v. Estrellita B. Clemente

Summary

This property dispute involved petitioner Manuel Aloria, a US resident, who discovered that his property in Caloocan City had been fraudulently transferred to respondent Estrellita Clemente through a forged deed of sale dated April 18, 2000. The trial court found the deed void and ordered reconveyance, but the Court of Appeals reversed, applying the presumption of regularity to the document. The Supreme Court ultimately granted the petition, finding clear evidence of forgery through signature comparison analysis. The Court established that the deed of sale was null and void, as petitioner's signature was demonstrably forged while he was residing in the United States. The case was remanded to determine proper reimbursement for improvements under Civil Code provisions governing possessors in good and bad faith. The decision clarifies that actions for reconveyance based on fictitious deeds do not prescribe, distinguishing such cases from challenges to original registration decrees under the Property Registration Decree.