The Heirs of Lope Malaque v. Heirs of Salomon Malaque

Summary

This case involves a family dispute over inherited land between siblings. The Heirs of Salomon Malaque sought partition of an 8,032-square meter property, claiming that deeds transferring ownership to their deceased brother Lope were forged and invalid. The respondents argued their signatures on a 1976 Deed of Quitclaim and a 1970 Deed of Absolute Sale were obtained through fraud. The RTC and CA initially ruled in favor of respondents, declaring the deeds void. However, the Supreme Court reversed, finding that respondents failed to prove forgery with the required quantum of evidence. The Court noted that during trial, respondents admitted signing the documents but claimed ignorance of their contents. Given the notarized deed's presumption of validity, petitioners' long possession and tax payments, and respondents' failure to specifically deny the sale deed under oath, the Supreme Court dismissed the complaint. This decision reinforces the evidentiary burden required to overcome the presumption of validity of notarized documents and emphasizes that forgery must be proven with clear, positive, and convincing evidence.