CASE DIGEST : MUNICIPALITY OF STA. MARIA v. CARLOS A. BUENAVENTURA G.R. No. 191278. March 29, 2023 GAERLAN

FACTS : The case arose from a complaint for sum of money and damages filed by the respondent against the Municipality of Sta. Maria, Bulacan, its mayor, and members of the Sangguniang Bayan after they allegedly constructed a public road over approximately 998.75 square meters of his registered property without his knowledge or consent. Although the parties initially negotiated a memorandum of agreement allowing the municipality to temporarily use the property, the Sangguniang Bayan refused to approve it. In defense, the petitioners claimed that the land had already been donated by the respondent to Barangay Guyong through a notarized Deed of Donation, which they relied upon in constructing the road. The Regional Trial Court dismissed the complaint, ruling that the notarized deed, being a public document, was presumed valid until annulled in a separate proceeding and that the municipality acted in good faith in relying on it.

On appeal, however, the Court of Appeals reversed the RTC's ruling, holding that the burden of proving the authenticity and applicability of the Deed of Donation rested upon the petitioners. The CA found that they failed to establish that the donated property was the same portion occupied by the road and that the respondent successfully demonstrated that his signature on the deed was forged. Consequently, the CA declared the municipality's occupation of the property unlawful and ordered the petitioners to remove the road, restore the property to its original condition, and pay the respondent temperate damages of ₱2,000 per month from June 2001 until the property is returned. The petitioners then elevated the case to the Supreme Court, raising the issues of the validity of the notarized Deed of Donation, the burden of proving forgery, and their alleged good faith in constructing the road.

ISSUE : 

1. Whether or not the notarized Deed of Donation being a public document is considered valid until nullified in a separate and proper proceeding;
   
   
2. Whether or not the burden of proof lies on the petitioners that the Deed of Donation is not a forgery.
   
   
3. Whether or not [the] petitioner municipality is in bad faith for constructing a road over the property covered by a notarized deed of donation and consequently pay rentals for its use

HELD : The Supreme Court partly granted the petition. It held that although a notarized document enjoys the presumption of regularity, such presumption was successfully overturned because the respondent proved by a preponderance of evidence that his signature on the Deed of Donation was forged. The Court found significant differences between the questioned signature and the respondent's genuine signatures and noted that the municipality's own actions, particularly the proposed MOA, implicitly recognized the respondent's ownership of the property.

However, the Court ruled that the removal of the road was no longer practical because it had already become a public road serving the community. Instead, the municipality was ordered to pay just compensation based on the property's fair market value at the time of taking, with legal interest, as well as ₱300,000.00 exemplary damages and ₱75,000.00 attorney's fees. The case was remanded to the RTC for the determination of the amount of just compensation.