Vicente Manzano, Jr. v. Marcelino Garcia

Summary

This case involved a dispute over the validity of a pacto de retro sale of a 6,951 square meter property in Cagayan de Oro City allegedly executed by Marcelino Garcia in favor of Constancio Manzano for P80,500. Garcia claimed the document was forged as he was in the United States when it was supposedly executed on May 26, 1992. The trial court initially ruled in favor of the buyer's heirs, but the Court of Appeals reversed, finding the sale void due to forgery. The Supreme Court affirmed, holding that expert testimony is not required when signature differences are obvious and that the testimonies of the notary public and witness, who both confirmed the signatory was an impostor, were credible. The Court noted the suspicious circumstances including the use of a wrong middle initial and the extremely low price for valuable city property, ultimately declaring the sale void ab initio for lack of genuine consent.