The case is styled Miguel Soriano, Jr. and Julieta Soriano (petitioners) versus Antero Soriano and Virginia Soriano (respondents), docketed as G.R. No. 130348. The petition before the Supreme Court is a Petition for Review on Certiorari under Rule 45 of the Rules of Court. Petitioners sought three principal remedies: (1) the reversal of the Court of Appeals' decision dated 18 August 1997 in CA-G.R. SP No. 44365; (2) the dismissal of the ejectment complaint filed by respondents; and (3) the issuance of a temporary restraining order enjoining the Metropolitan Trial Court (MeTC) and respondents from executing writs of execution and demolition in Civil Cases No. 3856 and No. 94-0001 pending final resolution of the petition. In short, the petition challenged both the procedural disposition by the appellate court (timeliness of the appeal) and the substantive finding that petitioners had violated the lease agreement by subleasing portions of the leased premises.

The original lease agreement was executed on 5 October 1981 between respondents Antero and Virginia Soriano as lessors and petitioners Miguel and Julieta Soriano as lessees. It covered a 420-square-meter parcel of land located in Pamplona, Las Piñas, Metro Manila, covered by Transfer Certificate of Title No. S33221. The lease was for a 20-year period. The leased property was intended as the site of a building to be constructed and used exclusively by the lessee. Crucially for this dispute, one of the lease provisions (Clause 6) expressly prohibited the lessee from subleasing or assigning the leased area or any portion thereof without first securing the written consent of the lessor. This no-sublease clause is the contractual prohibition at the center of the ejectment suit filed by respondents.

Respondents alleged that in December 1993 they discovered that petitioners, purportedly under the guise of being the owner, were subleasing the leased premises to third persons. They claimed to have secured a copy of a "Contract of Lease" dated 3 July 1993 executed between petitioners and a certain Marilou P. Del Castillo. Upon investigation, respondents asserted that various portions of the premises were being leased to a beauty parlor, photography shop, auto supply dealer, and a money changer—activities inconsistent with exclusive use by the lessee and done without plaintiffs' implied or express consent. Respondents sent petitioners a "Notice to Vacate" in December 1993, but contended that petitioners had not vacated the premises, prompting the filing of a complaint for ejectment on 24 February 1994 before the Metropolitan Trial Court (MeTC), Branch 79, Las Piñas, docketed as Civil Case No. 3856.

Respondents prayed for several remedies against petitioners: (1) that petitioners be ordered to vacate the premises covered by TCT No. S33221 and surrender possession; (2) that petitioners be ordered to pay respondents P2,662.00 per month for use of the premises from January 1994 up to the date petitioners vacated, plus 12% per annum with an increment of 10% every three years beginning 1994; and (3) payment of attorney's fees in the amount of P10,000.00 and P3,000.00 per appearance. These monetary and ejectment remedies formed the substantive relief sought in Civil Case No. 3856.

Respondents offered several pieces of evidence: (1) a copy of a contract of lease dated 3 July 1993 said to be executed by petitioners and Marilou P. Del Castillo; (2) an affidavit of Marilou P. Del Castillo corroborating the existence of the contract of lease between her and petitioners; (3) various affidavits of third parties who allegedly subleased portions of the subject property from petitioners; and (4) a Questioned Document Report by the National Bureau of Investigation (NBI) asserting that the signature of Marilou P. Del Castillo on the Joint Venture Agreement presented by petitioners was a forgery. The MeTC placed significant weight on Del Castillo's affidavit and the NBI report in concluding that a sublease had in fact been executed between petitioners and Del Castillo.

Petitioners denied violating the 1981 lease and disputed the existence of any sublease to Del Castillo and other third persons. They asserted that the relationships they had with Del Castillo and the other third parties were not subleases but joint venture agreements. Petitioners contended that the purported Contract of Lease dated 3 July 1993 was falsified, alleging that the signatures of petitioner Julieta Soriano, certain witnesses, and the notary public appearing on the document were forgeries. To support their narrative, petitioners presented what they characterized as a Joint Venture Agreement entered into between them and Marilou P. Del Castillo. Thus, their defense hinged on contesting the authenticity of the documentary evidence offered by respondents and recharacterizing the transactions as joint ventures rather than leases.

Civil Case No. 94-0001 was a case for consignation of rental fees filed by petitioners before the MeTC. Petitioners claimed respondents refused to encash checks representing rentals for the period January to June 1994, and therefore sought to consign those rentals. Because the consignation action and the ejectment complaint involved the same leased premises and intertwined factual questions—namely, whether petitioners were entitled to remain in possession and whether payments were due— the MeTC consolidated Civil Case No. 3856 (ejectment) and Civil Case No. 94-0001 (consignation) for purposes of trial and disposition, finding them closely related.

On 15 April 1996 the MeTC promulgated a Joint Decision rendered in favor of respondents. The dispositive ordered petitioners and all persons claiming rights under them to vacate the premises and surrender possession to respondents; it ordered petitioners to pay respondents P2,662.00 per month from January 1994 and thereafter until the premises were vacated; and awarded P10,000.00 as reasonable attorney's fees and costs of suit. The MeTC dismissed the consignation case and petitioners' counterclaim without pronouncement as to costs.

In reasoning, the MeTC found that the contract between petitioners and Del Castillo was a sublease and not a joint venture. The court gave strong weight to Del Castillo's affidavit that she had entered into a sublease with Julieta Soriano and to the NBI Questioned Document Report which declared the signature of Del Castillo on the Joint Venture Agreement presented by petitioners to be a forgery. The MeTC also discussed the parties' burden of proof, noting that petitioners, who challenged the genuineness of the subcontract of lease, bore the burden to prove forgery and had failed to wholly overcome the presumption of validity attached to the contract offered by respondents.

The MeTC applied the principle that a party who challenges the genuineness and due execution of a document bears the burden of proof to show that it is forged. The court observed that defendants (petitioners) failed to overcome the presumption of validity that attaches to contracts. Because plaintiffs (respondents) furnished affirmative proof—such as Del Castillo's affidavit and corroborating witnesses—tending to validate the sublease, the MeTC considered plaintiffs' positive evidence to be weightier than petitioners' negative denials. The court emphasized that defendants' negative assertions could not prevail over plaintiffs' positive proofs and that petitioners had not succeeded in disproving the authenticity or the contractual effect of the documents presented by respondents.

The MeTC dismissed the consignation claim on the ground that there was no valid tender of payment—one of the requisites for a proper consignation. The court found that petitioners had tendered checks representing rentals for January to June 1994 sometime in the third week of December 1993, but that those rentals were not yet due at that time. Because the tender prerequisite to consignation requires that the payments be due and the tender be valid, the MeTC concluded that petitioners' tender was premature and therefore invalid, warranting dismissal of the consignation action.

On appeal, the RTC, Branch 255, Las Piñas, affirmed the MeTC decision in toto. It placed particular emphasis on a letter dated 22 October 1993 from Ma. Lourdes R. Acebedo, Executive Vice-President of Acebedo Optical Co., Inc. The RTC interpreted this letter-proposal as embodying terms of a lease for the use of the front space of the establishment from October 23 to November 23, 1993, with an express amount to be paid and a daily electricity charge. Because the letter contained a "conforme" signature by Julieta Soriano, the RTC used it to bolster respondents' claim that portions of the premises were indeed leased or made available to third parties without respondents' concurrence, supporting the finding that petitioners violated the prohibition against subleasing.

The RTC promulgated its decision on 7 April 1997. Petitioners moved for reconsideration on 17 April 1997. The RTC denied the motion for reconsideration on 6 May 1997. Petitioners received a copy of that denial on 28 May 1997, while petitioners' counsel, Rico & Associates Law Office, received their copy on 2 June 1997. From the denial of the motion for reconsideration, the reglementary period to appeal or file a petition for review normally runs, but the record reveals contentions over when the period began to run because petitioners argued notices should have been sent to their counsel of record. Petitioners filed a "motion for extension of time to file petition for review" on 6 June 1997, and the petition for review to the Court of Appeals was filed (as determined by the Supreme Court) on 6 June 1997 — within the five-day remaining period counted from when their counsel of record received the denial on 2 June 1997. The RTC, however, issued an order on 20 June 1997 granting respondents' motion for execution, concluding the RTC decision had become final because no petition had been perfected within the appeal period as they interpreted it. The appellate court (Court of Appeals) ultimately denied the petition on 18 August 1997.

On 20 June 1997, the RTC granted respondents' Motion for Execution of Judgment dated 7 April 1997. The RTC observed that petitioners had been served with a copy of the decision on April 7 and that the defendants' motion for reconsideration of April 17 consumed 10 of the 15 calendar days available to perfect an appeal. The RTC found that the order denying the motion for reconsideration was received by petitioners through their counsel on May 28, leaving only five days to file a petition. Because no petition or appeal had been perfected by the date of the RTC order, and because an attorney for petitioners admitted no petition had been filed, the RTC concluded the decision had become final and executory. Citing Salientes v. Intermediate Appellate Court and related authorities, the RTC held that execution of decisions in ejectment cases falls within the jurisdiction of the inferior court and not the appellate court; thus it remanded the record to the MeTC, Branch 79, Las Piñas City, for execution of judgment.

The Court of Appeals rendered a decision on 18 August 1997 denying the petition for review and affirming the RTC's decision in toto. The Court of Appeals denied relief on two primary grounds: first, it concluded that the petition for review had been filed out of time because petitioners did not perfect their petition within the reglementary period; and second, on the merits it found that there was a contract of lease between petitioners and Marilou del Castillo which violated the no-sublease provision of petitioners' lease with respondents. The appellate court therefore upheld the rulings of the lower tribunals, denied petitioners' motion for extension of time as moot, lifted any injunction that had been granted, and assessed costs against petitioners.

Petitioners contended that the Court of Appeals misapplied the rules on service of court orders when it computed the reglementary period from the date when Atty. Miguel Soriano personally received a copy of the RTC's order denying the motion for reconsideration (May 28, 1997), rather than from the date when petitioners' counsel of record, Rico & Associates Law Office, received the same (June 2, 1997). Petitioners argued that Rico & Associates had formally entered its appearance as counsel of record in November 1995 and that it should have been the recipient of all court notices; thus notice to their counsel was effective notice to petitioners. They maintained that petitioner Atty. Miguel Soriano had never formally entered an appearance as counsel for himself and his wife, and that court notices should have been sent to the Rico & Associates address. They argued that counting time from May 28 unfairly penalized them and that their petition to the Court of Appeals was timely when measured from the counsel of record's receipt.

The Supreme Court applied the rule articulated in Section 2, Rule 13 of the 1997 Rules of Civil Procedure (as amended), which defines filing and service and prescribes that, if any party has appeared by counsel, service upon him shall be made upon his counsel or one of them unless service upon the party himself is ordered by the court. The Court emphasized the general principle that where a party is represented by counsel of record, notices required in the action must be given to that counsel, and service upon any person other than the counsel of record is not legally effective to start the corresponding reglementary period unless otherwise ordered. The Court made clear that notice should be made to counsel of record at the exact address provided and that the rules are designed to ensure parties are informed so they can take protective action—such as appealing—within the required time.

The Supreme Court concluded that Rico & Associates Law Office was the counsel of record for petitioners, and that the order denying petitioners' motion for reconsideration, having been served upon Rico & Associates on 2 June 1997, constituted the formal notice that started the running of the remaining five-day reglementary period. Because petitioners' counsel of record received the order on 2 June 1997, the last day to file the petition was 7 June 1997. The Court therefore held that the petition interposed before the Court of Appeals on 6 June 1997 was timely filed. The Court rejected respondents' position that counting should begin from 28 May 1997—when Atty. Miguel Soriano personally received a copy—because service on a non-counsel-of-record or on a collaborating counsel who had not formally entered an appearance cannot substitute for service on the counsel of record, absent a specific court order. The Supreme Court thus found the petition timely and that Section 2, Rule 13 required service on counsel of record.

The Supreme Court emphasized that petitioners had formally designated Rico & Associates Law Office as their counsel of record, with a stated office address, and that the practice in the case showed that correspondence, notices, and processes were regularly sent to that law office. Nothing in the record showed that Atty. Miguel Soriano had formally entered his appearance as collaborating counsel for petitioners; nor was there any court order directing that service be made upon him personally. The Court pointed out that rule 13 requires notices to be given to counsel of record and that service upon any other person is not legally effective to trigger the reglementary period. Because Rico & Associates was the counsel of record and received the order on 2 June 1997, service to that counsel started the appeal period. The Court further remarked that strict application of rules should not override substantial justice and noted that the pattern of serving documents to the law firm, except for the order denying reconsideration, underscored that the law firm was the appropriate recipient of service.

Yes. After resolving the procedural question of timeliness in petitioners' favor, the Supreme Court proceeded to address the substantive merits. The Court noted that petitioners were essentially asking it to re-evaluate factual determinations already made by three lower courts—the MeTC, the RTC, and the Court of Appeals—which had all affirmed that there existed a sublease between petitioners and Del Castillo. The Supreme Court recognized the limits of Rule 45: that it reviews only questions of law, not of fact, and that this Court is generally not expected to retry or reweigh evidence. The Court nonetheless reviewed the records and found no reversible error in the factual conclusions of the lower courts. It therefore affirmed the existence of a contract of (sub)lease between petitioners and Marilou P. Del Castillo and found that such sublease violated the 1981 lease's prohibition on subleasing. The Court's approach was to test whether any of the recognized exceptions permitting review of facts applied and to determine whether the lower courts' factual findings were supported by the record. Finding none of the exceptions present, and that the parties' signatures evidenced consent, the Supreme Court affirmed the rulings below.

The Supreme Court reiterated that under Section 1, Rule 45 of the Rules of Court, its jurisdiction on a petition for review on certiorari is limited to questions of law; it does not extend to reexamination of factual findings. The Court can review factual findings only under narrowly defined exceptions—such as when conclusions are based on speculation or surmise, are manifestly mistaken, involve grave abuse of discretion, are based on misapprehension of facts, are conflicting, lack citation of specific evidence, are contradicted by record evidence, are contrary to the findings of the trial court, overlook undisputed facts that would change the outcome, exceed the issues, or are contrary to admissions of the parties. The Court explicitly listed these exceptions in the decision, stating that absent any of them it would not disturb the factual determinations of the lower courts.

No. The Supreme Court reviewed the record and found none of the recognized exceptions that would permit it to re-evaluate or overturn the factual findings of the lower courts. The Court stated that none of the circumstances—such as findings based on conjecture, manifest error, grave abuse of discretion, misapprehension of facts, conflicting findings, lack of citation to specific evidence, contradiction by record evidence, material oversight of relevant facts, findings beyond the issues, or findings contrary to admissions—were present. Since the lower courts' findings were supported by the evidence on record, the Supreme Court declined to disturb those factual determinations and thus affirmed the existence of the sublease as concluded below.

The Supreme Court recognized—and the lower courts had found—that the contract of (sub)lease contained false signatures of the witnesses and the notary public. However, the Court explained that the presence of forged signatures of witnesses and notary does not necessarily negate the existence of a valid contract when the signatures of the contracting parties themselves are genuine. The Court reasoned that the law requires the consent of the contracting parties for a contract's perfection; signatures of witnesses or even a notary public are not essential elements for the validity of a contract between consenting parties. The Court noted the factual finding that Del Castillo acknowledged having signed the contract along with petitioner Julieta Soriano, and thus the agreement evidenced the requisite consent despite the forged ancillary signatures. Consequently, forged witness/notary signatures did not warrant a ruling that no valid contract existed between petitioners and Del Castillo.

The Supreme Court relied on several evidentiary points established in the record and accepted by the lower courts: Del Castillo's affidavit admitting she entered into a contract with petitioners and her testimony that she had signed the contract; the NBI Questioned Document Report that declared the signature on the Joint Venture Agreement to be a forgery (supporting the view that petitioners' proffered Joint Venture Agreement was not genuine); and corroborating affidavits of third parties. The Court noted that Del Castillo explained that when petitioners delivered the contract of lease to her, the witnesses' signatures were already on it and that Julieta Soriano had signed the name of the notary public and sealed the document with his notarial seal. The Court accepted the narrative that petitioners prepared the document and then presented it to Del Castillo to sign, thereby establishing the parties' consent necessary to form a valid contract of lease.

The Supreme Court expressly stated that had petitioners alleged and offered evidence demonstrating that the signatures of the parties to the contested contract—specifically petitioner Julieta Soriano and Marilou P. Del Castillo—were forgeries, the result would have been different. If the signatures of the contracting parties were forged, there would be an absence of consent between the parties, and hence no contract of (sub)lease would have been formed. Without a valid sublease, petitioners could not have been deemed to have violated the no-sublease clause of their lease with respondents. Thus, the Court made clear that the critical point is the genuineness of the parties' signatures: forged signatories would nullify the contract, whereas forged witness or notary signatures alone do not.

The petitioners argued that the instrument in question was a joint venture agreement and not a sublease, and thus did not violate the no-sublease clause of their 1981 lease. The Supreme Court observed, however, that this was essentially a challenge to the factual determinations of the lower courts as to the nature of the instrument. Given the MeTC's findings—supported by Del Castillo's affidavit and the NBI report indicating forgery in petitioners' version of a joint venture agreement—and the corroborative documentary evidence such as the Acebedo letter, the lower courts found the instrument to be a contract of lease (sublease). Because the Court of Appeals and RTC had already affirmed the MeTC's factual determinations and there were no exceptional circumstances warranting review of facts under Rule 45, the Supreme Court declined to reclassify the transaction as a joint venture. Thus the Court sustained the characterization of the agreement as a sublease and affirmed petitioners' violation of the lease prohibition on subleasing.

The Acebedo letter dated October 22, 1993 from Acebedo Optical Co., Inc. to "Ms. Julieta B. Soriano" proposed the use of the front space of petitioners' establishment for a project from October 23 to November 23, 1993, and offered P3,500.00 for the use, plus P20.00 per day for electricity. The letter bore a "conforme" signature signed "Julieta B. Soriano." The RTC gave premium to this letter and construed it as evidence that portions of the subject property were made available to third parties—here, Acebedo Optical—for commercial use without respondents' consent, supporting the conclusion that petitioners had engaged in subleasing. The letter was therefore instrumental in corroborating respondents' claims that petitioners allowed third-party commercial operations in the leased premises, contrary to the exclusive-use stipulation and the no-sublease clause in the 1981 lease.

The NBI Questioned Document Report (No. 843-1094) played an evidentiary role by stating that the signature of Marilou P. Del Castillo on the Joint Venture Agreement presented by petitioners was a forgery. This report undermined petitioners' attempt to characterize the transaction with Del Castillo as a joint venture, and bolstered respondents' case that the Joint Venture Agreement was not genuine and that the contract of lease submitted by respondents reflected the real transaction. The MeTC credited the NBI report together with Del Castillo's affidavit in concluding that petitioners' purported joint venture agreement lacked authenticity and that a sublease indeed existed. The report therefore weighed in favor of the respondents' narrative and affected the evaluation of competing documentary proofs by the courts below.

The courts, including the Supreme Court, acknowledged that the contested contract of (sub)lease contained false signatures of witnesses and the notary public. Nevertheless, they held that the mere presence of forged signatures of witnesses or a notary on a document prepared by a party does not automatically render presentation of such a document as a resort to falsehood by the opposing party who submitted it as evidence. The MeTC and the appellate courts reasoned that respondents merely offered the document as prepared and presented by petitioners; respondents did not fabricate the document themselves. The courts also stressed that the signatures of witnesses and of the notary serve primarily to make a contract binding against third parties; they are not essential to the existence of a valid contract between consenting parties. Hence, the fact that witnesses' and notary's signatures were forged did not defeat the evidentiary value of the document insofar as it reflected the actual consent of the contracting parties.

The MeTC concluded that the consignation claim failed because petitioners' tender of checks representing rentals for January to June 1994 occurred in the third week of December 1993—before the rentals were actually due. The court characterized such tender as premature and therefore not a valid tender as required for consignation. The MeTC emphasized that a valid tender must take place when payment is due, and since the rentals were not yet due at the time of the tender, the tender prerequisite of consignation was absent. Consequently the MeTC dismissed the consignation case. The Supreme Court affirmed that disposition, agreeing with the lower court's finding that there had been no valid tender and thus consignation was improperly invoked.

The Supreme Court denied the petition for review on certiorari and affirmed the Court of Appeals' decision of 18 August 1997 in CA-G.R. SP No. 44365. The Court found the petition to be timely filed and found no reversible error in the lower courts' factual determinations that a sublease existed between petitioners and Marilou P. Del Castillo in violation of petitioners' lease with respondents. The Court ordered costs against petitioners. In sum, the lower courts' judgments favoring respondents on the ejectment and monetary claims were left intact.

Several material legal principles guided the Court's resolution: Procedurally, the Court applied Section 2, Rule 13 of the Civil Procedure rules which mandates that service of judicial processes be made upon counsel of record when a party is so represented, and that service upon others does not trigger reglementary periods unless ordered. The Court stressed the presumption that counsel of record is the authorized recipient of court notices and that strict procedural rules should not defeat substantial justice.

Substantively, the Court followed the principle that a contract is perfected by the consent of contracting parties; signatures of witnesses or notaries are not essential to the existence of a contract between the parties themselves but primarily serve to bind the instrument against third parties. Therefore, forged signatures of ancillary signatories do not necessarily vitiate a contract if the contracting parties themselves consented and their signatures were genuine. The Court also relied on evidentiary rules regarding the burden of proof: the party who contests the genuineness of a document has the burden of proving forgery and cannot rest on negative denials when the opposing party presents affirmative evidence of authenticity.

The Court emphasized that rules of procedure are instruments to secure, not override, substantial justice. It held that a rigid application of procedural rules that would hamper rather than promote substantial justice was improper. In applying Section 2, Rule 13, the Court refused to permit a hyper-technical reading that would penalize petitioners despite their counsel of record having received the denial of reconsideration. By counting the reglementary period from the date counsel of record received the order (June 2) rather than the date a non-counsel collaborator received it (May 28), the Court ensured that procedural timing rules operated to secure, rather than defeat, petitioners' opportunity to seek appellate review. This approach reflects a pragmatic balancing where procedural compliance is enforced in a manner that advances fair adjudication rather than rigidly defeating parties on technicalities.

The Court's decision underlines two lessons. First, that for a contract's validity the essential element is the consent of the contracting parties; thus, proof that both parties genuinely signed the instrument is determinative for the existence of the contract. Signatures of witnesses or of a notary, while significant for publicity or enforceability against third parties, are not foundational to the contract's existence between the consenting parties. Second, when a party offers a document prepared by the opposing party and it bears forged ancillary signatures, the offering party does not automatically commit a fraud merely by presenting it; instead, courts will examine who prepared the document, the testimony of the contracting parties, forensic reports, and corroborative evidence to determine the true nature of the transaction. The burden remains upon the party asserting forgery to prove it, especially when the opposing side provides affirmative evidence of the parties' consent.

The Supreme Court accepted multiple factual findings made by the triers of fact: (1) that petitioners entered into a contract (sublease) with Marilou P. Del Castillo; (2) that Del Castillo acknowledged signing the contract and that her affidavit corroborated respondents' account; (3) that the signatures of the witnesses and the notary public on the sublease-related instruments were forged; (4) that petitioners permitted third parties to use portions of the leased premises (as evidenced by the Acebedo letter and affidavits), which violated the no-sublease clause of the 1981 lease; and (5) that petitioners' purported Joint Venture Agreement was suspicious and bore indicia of forgery as evidenced by the NBI Questioned Document Report. The Supreme Court found these findings sufficiently supported by the record and thus declined to disturb them under the Rule 45 constraints.

Advocating for petitioners from within the record, one would emphasize: (1) the apparent forgeries of signatures on material documents and the NBI report that questioned the authenticity of petitioners' Joint Venture Agreement. You would argue that the presence of multiple forged signatures creates a substantial question as to the true nature and authenticity of the instruments and that any reasonable doubt should weigh against enforcement of an alleged sublease. (2) Procedurally, you would stress the confusion in service and receipt of orders—arguing that petitioners and their counsel acted in a reasonable manner given the distribution of notices—and underline any ambiguity in the timeline to seek equitable relief or extension. Although the Supreme Court ultimately endorsed petitioners' timeliness, highlighting procedural irregularity could, in closer factual balancing, persuade a factfinder or appellate tribunal to scrutinize the lower courts' reliance on contested documents more critically. Both points attack the reliability of the primary proof of the sublease and the procedural circumstances surrounding the case.

Arguing for respondents, two strong points stand out: (1) affirmative evidence of a sublease and third-party occupation—most notably Del Castillo's affidavit admitting she signed a contract with petitioners and the Acebedo letter showing Julieta Soriano's "conforme" to allow third-party use—which directly supports respondents' claim that portions of the premises were subleased without consent. (2) The evidentiary basis that petitioners failed to prove forgery of the parties' own signatures: the courts noted that petitioners alleged forgery of witnesses and notary signatures but did not credibly show that the signatures of the contracting parties themselves (Del Castillo and Julieta Soriano) were forged. Because consent of the parties is the essence of a valid contract, respondents can assert that the contracting parties' signatures evidenced consent and therefore established a valid sublease in violation of the no-sublease clause. These points were persuasive to the MeTC, the RTC, the Court of Appeals, and ultimately the Supreme Court.

Petitioners sought the following reliefs from the Supreme Court: (1) reversal of the Court of Appeals decision dated 18 August 1997; (2) dismissal of respondents' complaint for ejectment; and (3) issuance of a temporary restraining order enjoining the MeTC and respondents from executing writs of execution and demolition issued in Civil Cases No. 3856 and No. 94-0001 until the present petition was finally resolved. The Supreme Court denied the petition in its entirety: it affirmed the Court of Appeals' decision, thereby leaving intact the ejectment judgment and its attendant monetary awards, and refused to grant the requested injunctive protections. Costs were assessed against petitioners. Therefore, none of the reliefs petitioners sought were granted.

This case illustrates several practical lessons: (1) the importance of formally entering the appearance of counsel of record and ensuring the court is precisely informed of that counsel's address, because service to the counsel of record is presumed effective and will commence procedural periods; (2) the need for counsel to monitor docket entries and ensure timely receipt of critical orders such as denials of motions for reconsideration, since the running of appeal periods depends on actual service to the counsel of record; (3) the value of promptly filing motions for extension of time or notices of appeal within the reglementary period counted from service upon counsel of record; and (4) maintaining and presenting credible documentary and testimonial evidence to prove or rebut forgery allegations, because courts will heavily weigh admissions of the parties (e.g., Del Castillo's affidavit) and forensic reports (e.g., NBI) in assessing authenticity and consent. Overall, precise procedural housekeeping and rigorous documentary proof are key to preserving appellate rights and substantive defenses.

The Supreme Court explicitly stated that, had petitioners produced evidence showing that the signatures of the contracting parties (Julieta Soriano and/or Marilou Del Castillo) were forged, the outcome would have been different. A finding that the parties' signatures were forged would mean there was an absence of consent, and therefore no valid contract of (sub)lease between petitioners and Del Castillo. Without a valid sublease, petitioners could not be held to have violated the prohibition against sublease in their lease with respondents, and the ejectment judgment premised on the existence of such a sublease would lack basis. Thus, a conclusive demonstration that the parties' signatures were forged would have negated the central substantive ground for ejectment in this case.

The Supreme Court denied the petition and affirmed the Court of Appeals' decision. The final disposition included an order that costs be assessed against petitioners. Thus, petitioners were made to bear the costs of the litigation at the Supreme Court level as well as the costs previously awarded by the lower courts, consistent with the affirmance of respondents' favorable judgments.

Three critical takeaways are: (1) Service on counsel of record is generally decisive. Under Rule 13, service upon the counsel of record is the proper and effective manner to commence procedural periods; parties should be careful to maintain accurate records of who is counsel of record and where notices are to be sent. (2) The essential element of contract formation is consent of the contracting parties; signatures of witnesses and notaries, while important, are not determinative of a contract's existence between the parties themselves. Allegations of forgery directed only at ancillary signatories do not automatically invalidate an instrument if the parties' signatures are genuine. (3) The Supreme Court's power in Rule 45 petitions is primarily to address questions of law, and it will not readily reexamine factual findings of lower courts unless narrow exceptions apply—students should therefore appreciate the high threshold for disturbing factual determinations on certiorari review.