Allegations of forgery in petitions seeking to correct official documents cannot be based on mere assertions and must instead be supported by clear and convincing evidence, the Supreme Court (SC) has ruled.
In a 12-page resolution written by Senior Associate Justice Marvic Leonen, the court’s Second Division affirmed a Court of Appeals ruling dismissing a petition filed by Lizza C. Santos to correct and cancel entries in a marriage certificate, citing her failure to prove the document was forged.
The case stemmed from a petition Santos filed in 2010 under the Rules of Court, seeking to correct entries in a marriage certificate registered with the Manila Local Civil Registrar. The document stated that she married Japanese national Yoshio Imai on 7 August 2010.
Santos asked the court to cancel several portions of the marriage certificate, including the section identifying the wife, the place and date of marriage, and her name and signature.
She maintained that she never married Imai and claimed she discovered the marriage certificate only in 2015 when she requested a Certificate of No Marriage. Santos alleged that her signature on the certificate had been forged.
To support her claim, Santos testified that she was working in Bulacan province on the day the marriage supposedly took place. She also presented testimonies from her mother, a neighbor and a co-worker.
However, the SC cited that Santos failed to submit crucial evidence that could have strengthened her allegations.
Among the deficiencies cited were her failure to present daily time records proving her whereabouts, her failure to include Imai in the proceedings and her failure to provide original signature specimens for scientific examination by the National Bureau of Investigation.
She also did not present expert handwriting testimony or independent documentary evidence to establish forgery.
Both the Regional Trial Court and the Court of Appeals previously dismissed her petition, prompting Santos to elevate the matter to the Supreme Court.
