Planters Development Bank v. Spouses Archimedes S. Inoncillo

Summary

This case involved a dispute over the validity of a mortgage agreement between Planters Development Bank (now China Bank Savings) and Spouses Archimedes and Liboria Inoncillo. The bank claimed the spouses authorized their brother Rolando to mortgage their property through Special Powers of Attorney to secure a P1.6M loan in 1997. The spouses denied executing any authorization and claimed their signatures were forged, asserting they were in the United States when the documents were executed. All three court levels found in favor of the spouses, with the trial court conducting a visual examination of the questioned signatures and finding them to be forgeries. The Supreme Court affirmed, emphasizing that forgery determinations are factual issues beyond its review jurisdiction in Rule 45 petitions. The case establishes that courts can independently assess handwriting evidence without expert testimony and reinforces the burden of proving forgery through clear, positive, and convincing evidence. The mortgage agreement was declared void ab initio, foreclosure was permanently enjoined, and attorney's fees were awarded.