Gomez vs. Gomez-Samson

In weighing conflicting expert testimony on questioned documents, a negative expert opinion — that no conclusion can be reached as to the sequence of handwriting and typewriting — may be more credible than a positive opinion when the authorities cited by both experts establish that intersecting ink lines are necessary for such a determination and the lines in question merely touch but do not intersect. The presumption of good faith and regularity of official acts cannot be overturned by conjecture and circumstantial evidence that fails to meet the standards for circumstantial evidence under the Rules of Court.

Consuelo Gomez, Ariston Gomez Sr., and Angel Gomez were siblings. Augusto Gomez is the son of Angel and was appointed Special Administrator of the Intestate Estate of Consuelo Gomez, who died on November 6, 1979. Maria Rita Gomez-Samson, Jesus B. Gomez, and Ariston B. Gomez Jr. are children of Ariston Sr. Two deeds of donation inter vivos purportedly executed by Consuelo on April 21, 1979, conveyed her real properties (Document No. 401) to Maria Rita and Jesus, and her personal properties (Document No. 402) to Ariston Sr. and Ariston Jr. Augusto, as special administrator, challenged the authenticity of both deeds, alleging that Consuelo's signatures had been forged or that the deed text had been intercalated onto blank sheets of paper she had previously signed.

Consuelo Gomez, Ariston Gomez Sr., and Angel Gomez were siblings. Augusto Gomez is the son of Angel and served as Special Administrator of the Intestate Estate of Consuelo, who died on November 6, 1979. Maria Rita Gomez-Samson, Jesus B. Gomez, and Ariston B. Gomez Jr. are children of Ariston Sr. Two deeds of donation inter vivos — Document No. 401 and Document No. 402 — purportedly executed by Consuelo on April 21, 1979, conveyed her real and personal properties to respondents. Document No. 401 covered three parcels of land in Marikina and Pasig, covered by Transfer Certificates of Title Nos. 340233, 353818, and 268396, donated to Maria Rita and Jesus. Document No. 402 covered seventy-five shares of stock in V-Tri Realty, Inc., 11,853 shares in First Philippine Holdings Corporation, jewelries and collector's items in a safe deposit box, two motor vehicles, and ₱200,000 in money market placements, donated to Ariston Sr. and Ariston Jr.

On February 15, 1980, Augusto filed two separate civil cases before the RTC of Pasig City. In Civil Case No. 36089, he alleged that after Consuelo's death, respondents Maria Rita and Jesus fraudulently prepared a deed of donation, forged Consuelo's signature, and antedated the notarial acknowledgment to April 21, 1979, then used the document to cancel Consuelo's titles and obtain new ones in their names. In Civil Case No. 36090, he made analogous allegations against Ariston Sr. and Ariston Jr., asserting that they had forged Consuelo's signature, antedated the notarial acknowledgment, and had already begun benefiting from the donated properties — Ariston Sr. using the vehicles and collecting dividends, and Ariston Jr. pre-terminating money market placements and receiving checks totaling ₱191,533.30. Respondents denied the allegations, asserting that the deeds were valid, that copies had been submitted to the Notarial Section of the CFI of Quezon City as early as July 2, 1979, and that ownership passed to them as early as April 20, 1979.

The cases were consolidated. The central factual dispute at trial was whether the deeds of donation had been intercalated onto blank sheets of paper previously signed by Consuelo. Petitioner presented Zenaida Torres, an NBI Document Examiner, as his principal expert witness. Torres testified that the signatures of Consuelo in both deeds were genuine but opined that the documents were not typed in one continuous sitting, citing variances in horizontal alignment, and that in Document No. 401, the typewritten name "Consuelo C. Gomez" was typed after the handwritten signature, based on her analysis of the letter "o" in the handwritten signature touching the typewritten letter "n." She could not make a similar finding for Document No. 402 because the typewritten and handwritten names did not even touch. On cross-examination, Torres admitted she had not taken specialized studies on questioned documents beyond one or two seminars, had not passed the Board Exams as a chemist, had never seen the typewriter used, and acknowledged that a loose paper roller could cause horizontal variance without anything sinister. She also admitted she had not used a typewriter pitch measure when photographing the documents, causing distortion upon enlargement.

Respondents presented Francisco Cruz, Chief of Document Examination at the PC-INP Crime Laboratory, who testified that both deeds were typed in one continuous sitting, based on consistent ink color tone, perfect vertical alignment, aligned left margins, and the use of an elite typewriter. Cruz explained that slight variances in horizontal spacing were due to the typist's use of the variable spacer button. As to whether the signature preceded the typing, Cruz testified, citing authorities, that it was impossible to determine which came first because the typewritten and handwritten names did not intersect — a prerequisite for such a determination under the recognized authorities on questioned documents. Respondents also presented the testimony of Notary Public Jose Sebastian, who stated that Consuelo signed the deeds in his presence on April 21, 1979, and that the documents were reported to the Notarial Registrar on July 2, 1979, four months before Consuelo's death.

The trial court found Cruz's testimony more credible than Torres's and dismissed the complaints, awarding moral damages of ₱1,000,000, exemplary damages of ₱250,000, and attorney's fees of ₱200,000 against Augusto and the estate of Consuelo, jointly and solidarily, in favor of Ariston Jr. The Court of Appeals affirmed in toto. Augusto then filed the present Petition for Review on Certiorari, raising nine issues challenging the CA's factual findings and its appreciation of the expert testimony, the alleged irregularities on the face of the deeds, the timing of the donor's tax payment, the credibility of Jose Sebastian, and the sufficiency of the circumstantial evidence.

• Exceptions to Factual Findings Rule: Petitioner argued that the case fell under several recognized exceptions to the rule that the CA's factual findings are binding on the Supreme Court, including when the inference made is manifestly mistaken, when the judgment is based on a misapprehension of facts, and when the CA overlooked relevant facts that would justify a different conclusion.
• Credibility of Expert Witnesses: Petitioner maintained that the positive testimony of NBI expert Zenaida Torres — that the handwritten signatures preceded the typewritten text — should prevail over the negative testimony of Francisco Cruz, who could only state that no conclusion could be reached. Petitioner also argued that Torres was a court-appointed expert and had examined the carbon originals from the notarial registry, whereas Cruz was designated by respondents and examined only the original in Ariston Jr.'s possession.
• Patent Irregularities on the Deeds: Petitioner argued that the deeds bore patent irregularities indicating falsification, including the use of letter-size rather than legal-size paper, single-spaced typing with barely any margins, the inclusion in Document No. 402 of a bodega not owned by Consuelo, the signatures appearing at almost the same place when the two deeds were superimposed, the use of one typewriter for the entire document including the notarial acknowledgment, and the preparation of insufficient copies.
• Donor's Tax Payment: Petitioner argued that the CA erred in finding that Consuelo herself paid the donor's tax on October 9, 1979, contending that the evidence showed the tax was paid on December 4, 1979, a month after Consuelo's death, as evidenced by the BIR certification stating payment "on even date" and the consecutive numbering of the revenue tax receipts.
• Credibility of Jose Sebastian: Petitioner claimed that no credence should be given to Jose Sebastian's testimony because he was the same judge dismissed from the service in an administrative case, casting grave doubt on his credibility, and that his November 22, 1979 certification was a scheme to mention the deeds of donation after Consuelo's death.
• Unusual Circumstances of Execution: Petitioner argued that the execution and notarization of the deeds on April 21, 1979 — the same day Consuelo left for the United States — was highly improbable given the limited time frame, that the choice of an unfamiliar notary public from Quezon City was suspect, that the belated transfer of properties after Consuelo's death was suspicious, and that all instrumental witnesses were biased relatives of the donees.
• Sufficiency of Circumstantial Evidence: Petitioner contended that the totality of circumstantial evidence produced a single network of circumstances establishing the simulation and falsification of the deeds of donation.
• Liability for Damages: Petitioner implicitly challenged the award of damages by arguing that his institution of the case was carried out in good faith and that his evidence successfully raised doubts as to the authenticity of the deeds.

• Validity of the Deeds: Respondents countered that the deeds of donation were valid, not forged, and that copies had been submitted to the Notarial Section of the CFI of Quezon City as early as July 2, 1979, four months before Consuelo's death.
• Credibility of Francisco Cruz: Respondents argued that Cruz's negative finding — that no conclusion could be reached as to the sequence of writing — was consistent with the authorities on intersecting ink lines, which require actual intersection for any determination, and that the typewritten and handwritten names merely touched (Document No. 401) or did not even touch (Document No. 402).
• Explanation for Irregularities: Respondents explained that the alleged irregularities in the deeds were due to the inexperience of Ariston Jr., a non-lawyer who prepared the documents, and that none of the irregularities affected the validity of the deeds or connoted fraud.
• Payment of Donor's Tax: Respondents presented documentary evidence — including a covering letter to the BIR dated September 24, 1979, the Donor's Tax Return received by the BIR on October 8, 1979, a PCIB check issued by Consuelo on October 9, 1979, and an "Authority to Issue Tax Receipt" dated October 21, 1979 — to prove that the donor's tax was paid during Consuelo's lifetime.
• Credibility of Jose Sebastian: Respondents pointed out that Sebastian was originally presented as a witness by the petitioner, and that under Rule 132, Section 12 of the Rules of Court, a party may not impeach his own witness except by contradictory evidence or prior inconsistent statements, and never by evidence of bad character.
• Belated Transfer of Properties: Respondents explained that the delay in transferring the real properties to their names was due to delicadeza — Maria Rita testified that she did not want to transfer the titles while Consuelo was still alive — and that under Article 712 of the Civil Code, ownership was acquired by donation, not by the issuance of new titles.

• Applicability of Exceptions to Factual Findings Rule: Whether the instant petition presents exceptions to the general rule that findings of fact of the Court of Appeals are binding on the Supreme Court.
• Credibility of Expert Testimony: Whether the Court of Appeals erred in giving more weight to the negative expert testimony of Francisco Cruz over the positive expert testimony of NBI examiner Zenaida Torres.
• Patent Irregularities on the Deeds: Whether the alleged patent irregularities on the face of the deeds of donation constitute evidence of falsification or intercalation.
• Donor's Tax Payment: Whether the Court of Appeals erred in finding that Consuelo herself paid the donor's tax on October 9, 1979, during her lifetime.
• Credibility of Jose Sebastian: Whether the Court of Appeals erred in giving credence to the testimony of notary public Jose Sebastian, who had been administratively dismissed from the service.
• Unusual Circumstances of Execution: Whether the Court of Appeals erred in disregarding the unusual circumstances surrounding the execution and notarization of the deeds of donation.
• Sufficiency of Circumstantial Evidence: Whether the totality of circumstantial evidence presented by petitioner established the simulation and falsification of the deeds of donation.
• Liability for Damages: Whether the award of moral damages, exemplary damages, and attorney's fees against the petitioner was proper.

• Applicability of Exceptions to Factual Findings Rule: No. The factual findings of the trial court, as affirmed by the Court of Appeals, were binding on the Supreme Court, none of the recognized exceptions being applicable.
• Credibility of Expert Testimony: No. The negative expert testimony of Francisco Cruz — that no conclusion could be reached as to the sequence of writing — was more credible than the positive testimony of Zenaida Torres, because it was consistent with the authorities on intersecting ink lines, which require actual intersection for any determination, and the typewritten and handwritten names merely touched or did not touch at all.
• Patent Irregularities on the Deeds: No. The alleged irregularities — use of letter-size paper, single-spaced typing, small margins, inclusion of a bodega not owned by Consuelo — were more apparent than real and did not affect the validity of the deeds or connote fraud, being adequately explained by the inexperience of Ariston Jr., a non-lawyer who prepared the documents.
• Donor's Tax Payment: No. The evidence on record — including the Donor's Tax Return received by the BIR on October 8, 1979, the PCIB check issued by Consuelo on October 9, 1979, and the "Authority to Issue Tax Receipt" dated October 21, 1979 — supported the finding that the donor's tax was paid during Consuelo's lifetime, and petitioner failed to present contrary evidence or rebut the presumption of regularity of official acts.
• Credibility of Jose Sebastian: No. Jose Sebastian was originally presented as a witness by the petitioner and could not be impeached by the party who called him under Rule 132, Section 12 of the Rules of Court; his subsequent administrative dismissal did not suffice to discredit his testimony, which was supported by the notarial registry records showing receipt of the documents on July 2, 1979.
• Unusual Circumstances of Execution: No. The circumstances surrounding the execution and notarization of the deeds were adequately explained by respondents — the choice of an unfamiliar notary public was due to Consuelo's desire for confidentiality, the time frame was sufficient, and the belated transfer of properties was due to delicadeza — and none of the circumstances, individually or collectively, established fraud.
• Sufficiency of Circumstantial Evidence: No. The circumstantial evidence failed to comply with the requirements of Section 4, Rule 133 of the Rules of Court, as the combination of all circumstances was not such as to produce a conviction or overturn the presumption of good faith.
• Liability for Damages: No. The award of moral damages, exemplary damages, and attorney's fees was deleted because petitioner's institution of the case was carried out in good faith, and in the absence of moral damages, exemplary damages could not be granted.

• Applicability of Exceptions to Factual Findings Rule: Findings of fact of the trial court, especially when affirmed by the Court of Appeals, are binding on the Supreme Court. Petitioner invoked five recognized exceptions — manifestly mistaken inference, grave abuse of discretion, misapprehension of facts, overlooked relevant facts, and findings premised on absence of evidence — but the Court found none applicable. The CA's findings were grounded on a thorough examination of the expert testimony and the documentary evidence, and petitioner failed to demonstrate that the CA's inferences were mistaken, absurd, or impossible.

• Credibility of Expert Testimony: While positive evidence is generally more credible than negative evidence, the rationale for this rule — that a witness testifying to a negative may have forgotten what occurred — does not apply to expert witnesses, who examine documentary evidence precisely to testify on their findings. The Court therefore examined the process by which each expert arrived at their conclusions. Torres based her positive finding that the signature preceded the typing solely on a single handwritten letter "o" touching the typewritten letter "n" in Document No. 401, without any intersection. The authorities cited by both experts — Wilson Harrison's Suspect Documents and another treatise on sequence of writing — establish that intersecting ink lines are necessary for determining the order of writing, and that a single indifferent intersection rarely produces a clear indication. Because the typewritten and handwritten names barely touched (Document No. 401) or did not touch at all (Document No. 402), Cruz's negative finding was more consistent with the authorities. Torres's testimony was further discredited by her admission that she had not taken specialized studies, had not seen the typewriter, and had not used a typewriter pitch measure when photographing the documents. The trial court's assessment of expert credibility, having observed the witnesses' demeanor, was accorded great weight and was not reviewable absent abuse of discretion.

• Patent Irregularities on the Deeds: The alleged irregularities — use of letter-size paper, single-spaced typing, small margins, inclusion of a bodega not owned by Consuelo, signatures appearing at the same place on both deeds, use of one typewriter for the entire document, and insufficient copies — were more apparent than real. None affected the validity of the deeds or connoted fraud. Legal documents on letter-size paper and single-spaced documents are not uncommon. The use of one typewriter for the entire document, including the notarial acknowledgment, is common practice. The small margins, while indicative of sloppiness, were explained by Ariston Jr.'s intentional choice of brevity. The lack of copies was explained by the loss of some duplicate originals — Maria Rita testified that her handbag was stolen in Spain, and Jose Sebastian inadvertently retained the original of Document No. 402 instead of a duplicate. The inclusion of a bodega not owned by Consuelo was the only observation that gave the Court genuine doubt, but it was insufficient to establish fraud. Good faith is always presumed, and the burden of proving bad faith lies with the party alleging it. Moreover, Ariston Jr. was never confronted during trial with these alleged irregularities, depriving the trial court of the opportunity to assess his explanation.

• Donor's Tax Payment: The factum probandum petitioner sought to establish was the intercalation of the deeds on blank paper. The factum probans — the alleged payment of the donor's tax after Consuelo's death — even if proven, would not establish the factum probandum, as payment of the tax after death does not necessarily prove intercalation. Petitioner also failed to prove the factum probans. Ariston Jr. testified that the PCIB check was prepared and issued by Consuelo during her lifetime but that he personally delivered it to the BIR. Respondents presented a covering letter dated September 24, 1979, the Donor's Tax Return received by the BIR on October 8, 1979, the PCIB check dated October 9, 1979, and an "Authority to Issue Tax Receipt" dated October 21, 1979. Petitioner merely formulated conjectures based on the consecutive numbering of the RTRs and the phrase "on even date" in the BIR certification, without presenting Nestor Espenilla to explain these matters or presenting evidence that the BIR records were falsified. The presumption of regularity of official acts thus stood unrebutted.

• Credibility of Jose Sebastian: Jose Sebastian was originally presented as a witness by the petitioner. Under Rule 132, Section 12 of the Rules of Court, a party may not impeach his own witness, except by contradictory evidence or prior inconsistent statements, and never by evidence of bad character. Sebastian was never declared an unwilling or hostile witness. Even if he had been, impeachment by evidence of bad character is prohibited. His subsequent administrative dismissal as a judge — which occurred eleven years after his testimony — could not be used to discredit him. Convicted criminals are not excluded from testifying, and the fact of prior conviction alone does not suffice to discredit a witness. Sebastian's testimony was supported by the notarial registry records, which showed that the documents were received on July 2, 1979, four months before Consuelo's death.

• Unusual Circumstances of Execution: The Court found nothing suspicious in a person wanting to transfer properties by donation before leaving for abroad. The claim that Consuelo's flight was at 11:00 a.m. was hearsay thrice removed — petitioner was told by his twelve-year-old son, who learned it from Consuelo's maid — and was contradicted by Maria Rita's positive testimony that the flight was at 1:00 p.m. The three-hour time frame was sufficient, and the Court took judicial notice that traffic is minimal on Saturday mornings. The choice of a notary public from Quezon City was explained by Consuelo's desire for confidentiality — she did not want to use her regular notary public, Atty. Angeles, because relatives she disliked had access to him. The belated transfer of properties did not affect the validity of the donations, as ownership was acquired by donation under Article 712 of the Civil Code, not by the issuance of new titles. The remaining allegations — payment in cash, the suggestion that Consuelo should have made a will, and the bias of instrumental witnesses — were purely speculative.

• Sufficiency of Circumstantial Evidence: The circumstantial evidence failed to comply with the requirements of Section 4, Rule 133 of the Rules of Court, which requires (a) more than one circumstance, (b) facts from which inferences are derived are proven, and (c) the combination of all circumstances produces conviction beyond reasonable doubt. In civil cases, the circumstances must not only be consistent with the proposition asserted but also inconsistent with any other rational theory. Petitioner succeeded only in raising doubts, which is insufficient in civil cases where the burden is preponderance of evidence. When the scales stand in equipoise, the court must find for the defendant. The presumption of innocence and good faith stands unrebutted.

• Liability for Damages: The Court's own examination of the records convinced it that petitioner's institution of the case was carried out in good faith. Petitioner's evidence successfully raised doubts as to the authenticity of the deeds, even though those doubts were insufficient to discharge his burden of proof. The subpoenas directed against respondents demonstrated the zealous efforts of petitioner's counsel and could not be taken against counsel or client. Having failed to prove bad faith, petitioner could not be held liable for moral damages. In the absence of moral, temperate, liquidated, or compensatory damages, exemplary damages could not be granted. Attorney's fees, which were predicated on the civil action being clearly unfounded, were likewise deleted.

• Weight of Expert Testimony — Courts are not bound by expert testimony and may give or refuse to give it any value as proof, or counterbalance it with other evidence. The relative weight and sufficiency of expert testimony is within the province of the trial court, which is in a better position to observe the demeanor of witnesses. The trial court's determination is not reviewable absent abuse of discretion. In this case, the Court applied the doctrine by examining the process by which each expert arrived at their conclusions and finding the negative expert testimony more credible because it was consistent with the authorities cited by both experts.

• Positive vs. Negative Evidence — As a general rule, positive evidence is more credible than negative evidence, because a witness who testifies to a negative may have forgotten what occurred, while it is impossible to remember what never existed. However, this rationale does not apply to expert witnesses, who examine documentary evidence precisely to testify on their findings. The Court held that while positive evidence retains an inherent advantage, the process by which expert witnesses arrive at their conclusions must be carefully examined.

• Presumption of Good Faith — Good faith is always presumed, and the party alleging bad faith bears the burden of proving it. In this case, petitioner failed to discharge this burden, and the presumption of good faith on the part of respondents and the presumption of regularity of official acts stood unrebutted.

• Equipoise Rule — When the scales stand in equipoise and there is nothing in the evidence that inclines it to one side or the other, the court will find for the defendant. The plaintiff must rely on the strength of his own evidence and not on the weaknesses of the defendant's claim. Even if the plaintiff's evidence is stronger than the defendant's, there is no preponderance if such evidence is insufficient to establish the cause of action.

• Impeachment of One's Own Witness — Under Rule 132, Section 12 of the Rules of Court, a party producing a witness may not impeach that witness's credibility, except by contradictory evidence or prior inconsistent statements, and never by evidence of bad character. A witness may be declared unwilling or hostile only upon adequate showing of adverse interest, unjustified reluctance, or having misled the party into calling him.

• Circumstantial Evidence Standards — Under Section 4, Rule 133 of the Rules of Court, circumstantial evidence is sufficient for conviction if (a) there is more than one circumstance, (b) the facts from which the inferences are derived are proven, and (c) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. The circumstances must be consistent with the proposition asserted and inconsistent with any other rational theory.

• "In the case at bar, therefore, the expert testimony that 'no finding or conclusion can be arrived at,' was found to be more credible than the expert testimony positively stating that the signatures were affixed before the typing of the Deeds of Donation. The former expert testimony has proven to be more in consonance with the authorities cited by both experts." — This passage articulates the ratio decidendi on the central issue of expert testimony credibility, establishing that a negative expert finding may prevail over a positive one when it is more consistent with the governing authorities.

• "While the above provision seems to refer only to criminal cases, it has been pointed out that in some jurisdictions, no distinction is made between civil and criminal actions as to the quality of the burden of establishing a proposition by circumstantial evidence. In such jurisdictions the rule is generally stated to be that the circumstances established must not only be consistent with the proposition asserted but also inconsistent with any other rational theory." — This passage defines the standard for circumstantial evidence in civil cases, requiring that the circumstances be inconsistent with any rational theory other than the one asserted.

• "All petitioner has succeeded in doing is to instill doubts in our minds. While such approach would succeed if carried out by the accused in criminal cases, plaintiffs in civil cases need to do much more to overturn findings of fact and credibility by the trial court, especially when the same had been affirmed by the Court of Appeals." — This passage distinguishes the burden of proof in civil cases from criminal cases, emphasizing that raising reasonable doubt is insufficient for a civil plaintiff.

• "When the scales shall stand upon an equipoise and there is nothing in the evidence which shall incline it to one side or the other, the court will find for the defendant." — This passage states the equipoise rule, a fundamental principle in civil litigation that the plaintiff bears the burden of preponderance and cannot rely on the weakness of the defendant's evidence.

• United States vs. Trono, 3 Phil. 213 (1904) — Cited for the proposition that courts are not bound by expert testimony and may weigh it freely, giving or refusing to give it value as proof. This case established the foundational principle governing the treatment of expert witnesses in Philippine jurisprudence.

• Espiritu vs. Court of Appeals, 312 Phil. 431 (1995) — Cited for the rule that the relative weight and sufficiency of expert testimony is within the province of the trial court to decide, considering the witness's ability, character, demeanor, possible bias, and status as a paid witness. The trial court's ruling is not reviewable absent abuse of discretion.

• Salomon vs. Intermediate Appellate Court, G.R. No. 70263, May 14, 1990, 185 SCRA 352 — Cited alongside Espiritu for the same proposition regarding the discretion of the trial court in evaluating expert testimony.

• People vs. Dominguez, G.R. No. 100199, January 18, 1993, 217 SCRA 170 — Cited for the principle that even convicted criminals are not excluded from testifying, and that prior criminal conviction alone does not suffice to discredit a witness. Applied to support the admissibility and credibility of Jose Sebastian's testimony despite his subsequent administrative dismissal.

• Sapu-an vs. Court of Appeals, G.R. No. 91869, October 19, 1992, 214 SCRA 701 — Cited for the equipoise rule: when the evidence stands in equipoise, the court must find for the defendant, and the plaintiff must rely on the strength of his own evidence, not the weakness of the defendant's claim.

• Garciano vs. Sebastian, A.M. No. MTJ-89-4-371, March 30, 1994, 231 SCRA 588 — The administrative case in which Jose Sebastian was dismissed from the service. Petitioner cited it to impugn Sebastian's credibility, but the Court held it inapplicable because the administrative sanction was imposed eleven years after his testimony and could not be used to impeach a witness called by the party seeking to impeach.

• Rule 132, Section 12, Rules of Court — Provides that a party may not impeach his own witness, except by contradictory evidence or prior inconsistent statements, and never by evidence of bad character. Applied to bar petitioner from impeaching Jose Sebastian, whom petitioner had originally called as a witness, by reference to Sebastian's subsequent administrative dismissal.

• Section 4, Rule 133, Rules of Court — Sets the standard for sufficiency of circumstantial evidence: (a) more than one circumstance, (b) the facts from which inferences are derived are proven, and (c) the combination of all circumstances produces conviction beyond reasonable doubt. Applied to hold that petitioner's circumstantial evidence was insufficient to establish falsification of the deeds.

• Article 712, Civil Code — Provides that ownership and other real rights over property are acquired and transmitted by donation, by testate and intestate succession, and in consequence of certain contracts, by tradition. Applied to explain that the donees acquired ownership by donation, not by the issuance of new titles, and that the belated transfer of titles did not affect the validity of the donations.

• Rule 131, Section 3(a), Rules of Court — Establishes the presumption that a person is innocent of crime or wrong. Applied to uphold the presumption of good faith in favor of respondents, which petitioner failed to rebut.

• Article 527, Civil Code — Provides that good faith is always presumed. Applied to place the burden of proving bad faith on the petitioner, who failed to discharge it.

Consuelo Ynares-Santiago (Associate Justice, Chairperson), Ma. Alicia Austria-Martinez (Associate Justice), and Romeo J. Callejo, Sr. (Associate Justice) concurred in the decision.