Tamani vs Salvador

FACTS: Demetrio Tamani sold a parcel of land to Milagros Cruz, who in part sold it to Salvador. This
prompted Salvador to file a case for quieting of title against the Tamanis, presenting a deed of sale
executed by Tamani to Cruz.

Tamani presented the NBI handwriting witness Albacea, who concluded that there was no forgery in the
deed of sale.

Tamani presented another witness, Sorra, who said that there was a forgery.

The RTC adopted Sorra’s testimony, claiming that she had better credentials.

The CA reversed the RTC, claiming that when confronted with conflicting testimonies from two expert
witnesses, it should have conducted its own investigation.

ISSUE: When presented with conflicting testimony from two expert witnesses, what must be given
weight?

RULING: The court must make an independent judgment, when presented with conflicting testimony
from two expert witnesses. It was erroneous for the RTC to simply adopt Sorra’s testimony, on grounds
that she had better credentials.

Further the Court ruled that “the value of the opinion of a handwriting expert depends not upon his
mere statements of whether a writing is genuine or false, but upon the assistance he may afford in
pointing out distinguishing marks, characteristics and discrepancies in and between genuine and false
specimens of writing which would ordinarily escape notice or detection from an unpracticed observer”.

In the case at bar, the Court gave credence to Sorra’s conclusions. This was because Albacea’s evidence
were from the entire period of 1933 to 1974, which afforded a lot of time for the changes in the
signature. Sorra’s examination of signatures on the other hand were from ones dating in 1957, when the
alleged deed of sale was executed. Thus, the examination was more in conformity with the subject
contract, which was executed on 1957 as well.