1. IRIS RODRIGUEZ V. YOUR OWN HOME DEVELOPMENT CORPORATION (YOHDC), G.R. No.

199451. August 15, 2018.

FACTS:

This case originated from a low-cost housing project in Occidental Mindoro, which YOHDC entered into
with its partner, Archangel Corporation. Iris' husband, Tarcisius Rodriguez (Tarcisius), was hired as the
project coordinator/manager. He found a property owned by Rosa Rosillas (Rosillas) and proceeded to
negotiate with her. According to YOHDC, Rosillas agreed to sell the land for P1,200,000.00. However,
Tarcisius misrepresented to the partner corporations that Rosillas had asked for P4,000,000.00 instead.
Tarcisius requested 4 excess checks from YOHDC to pay Rossillas and the surveyor of the property but
instead of delivering the same to them, Tarcisius and his wife, Iris, deposited a total of P754,400.00 in
their personal Bank of the Philippine Islands (BPI) Account No. 3293-0730-06. The other two (2) checks
were deposited in the Rodriguez Spouses' other personal bank account, BPI Account No. 0065-0506-25.

Upon investigation, it was found that the endorsement signatures on the checks of the intended payees,
Rosillas and Delos Reyes, were different from those on file. Moreover, while the checks were for two (2)
different people for Rosillas who lived in Bulacan and for Delos Reyes who was from Mindoro they were
deposited in the same BPI accounts. It must be noted that during this time, Iris worked as a bank teller
at BPI. This prompted YOHDC to contact Rosillas and Delos Reyes regarding the checks. Both confirmed
that they never received, endorsed, encashed, or deposited any of the four (4) checks.

YOHDC demanded from Tarcisius the amount of the checks which he failed to return so YOHDC pursued
its claim against the banks. YOHDC first sought reimbursement from Metrobank, which advised it to
direct its claim against BPI. BPI suggested that YOHDC course its documents through Metrobank.
Pursuant to Metrobank's instructions, YOHDC submitted Rosillas' and Delos Reyes' Checks and affidavits
to Metrobank, which, in turn, forwarded them to BPI. The latter then advised the Rodriguez Spouses to
deposit the amount of P1,508,800.00 in their BPI bank account so that it could respond to YOHDC's
complaint. Rodrigues spouses complied but requested BPI suspend its action on YOHDC's claim and
instructed it not to deduct the amount until they have clarified the matter. BPI denied this request and
sent Metrobank Special Clearing Receipt No. 065273 to reimburse the amounts of the four (4) checks
totaling P1,508,000.00. Thereafter, Metrobank credited the amount to YOHDC.

These events prompted the Rodriguez Spouses to file a Complaint for Damages against YOHDC, BPI,
Metrobank, Rosillas, and Delos Reyes, among others claiming that Rosillas' Checks were received by
Rosillas' agent, Syquioco. As for Delos Reyes' Checks, the Rodriguez Spouses asserted that Delos Reyes
received P424,000.00 from the proceeds of Metrobank Check.

RTC dismissed the case. On appeal, the same was modified and CA found that principle against unjust
enrichment did not apply. It did not lend credence to Delos Reyes' admission in his Answer regarding an
Acknowledgement dated June 9, 1995, which he allegedly signed (Delos Reyes' Acknowledgement). It
found that the document is a private document, the execution and authenticity of which were not
proven as required by the rules of evidence. Thus the CA frond that YOHDC was not liable to the
Rodriguez Spouses for P424,000.00 as well as attorney's fees.

Iris, in the instant petition argues that in Delos Reyes' Answer filed with the Regional Trial Court, he
admitted the existence of his Acknowledgment and receipt of the amount of P424,000.00. She claims
that the subsequent execution of his July 9, 1995 Answer and of his June 9, 1995 Acknowledgment
constitutes an abandonment of his March 14, 1995 Affidavit, where he denied the receipt or
encashment of his Checks.

ISSUE: Whether or not Court of Appeals rightfully lent more credence to Delos Reyes' Affidavit

RULING: Yes. This Court affirms the ruling of the Court of Appeals and gives more credence to Delos
Reyes' Affidavit, which is a public document.

A notarized document is presumed valid, regular, and genuine. It carries evidentiary weight with respect
to its due execution. As such, it need not be proven authentic before it is admitted into evidence. On its
face, it is entitled to full faith and credit, and is deemed to be in full force and effect.

To nullify a notarized document on account of flaws and defects, there must be a strong, complete, and
conclusive proof of its falsity. The required quantum of proof is a clear, strong, and convincing evidence.

In contrast, private documents must first be authenticated before they could be admitted in evidence.
To establish their authenticity, the best proof available must be presented.

However, authentication may not be necessary where the document's genuineness and due execution
were admitted by the adverse party.

However, this rule presents a caveat m that the admission of the document's authenticity must be
categorical.

In the case at bar, Delos Reyes' Acknowledgement is a private document. Thus, for Iris to rely on it, she
must have first proven its genuineness and authenticity by presenting the best proof available. As such,
she should have presented Delos Reyes to testify on its genuineness and due execution. However, Iris
merely relied on Delos Reyes' Answer and Acknowledgement on their faces. Delos Reyes neither
appeared in court to attest to the allegations of his Acknowledgement or to explain his Answer, nor
presented as Iris' witness.

Assuming that the statements in Delos Reyes' Answer are binding admissions, these admissions only
pertain to the existence of his Acknowledgment. He neither categorically stated its genuineness and
authenticity, nor admitted its allegations.

Moreover, this Court notes that Delos Reyes never denied his notarized Affidavit's allegations even
though his Acknowledgement's allegations are inconsistent with them.

Hence, this Court assumes that the Acknowledgement is in the nature of a retraction. This Court has
consistently held that retractions are looked upon with disfavor because of its unreliable nature and the
likely probability that it may again be repudiated.

The only logical explanation that could reconcile the two (2) documents is if this Court assumes that the
Rodriguez Spouses paid Delos Reyes the amount of P424,000.00 sometime after he executed his
Affidavit. However, if this is the case, that payment on behalf of YOHDC is not authorized since the
Rodriguez Spouses did not represent YOHDC in any manner. Moreover, it can be assumed that Tarcisius'
authority to represent YOHDC had been impliedly revoked considering the incidents on Delos Reyes' and
Rosillas' Checks.
Thus, if Delos Reyes was paid by the Rodriguez Spouses on behalf of YOHDC, this payment is
unauthorized. Iris' cause of action is with Delos Reyes, and not with YOHDC.

Petition denied.