Judge: Michael Shultz, Case: TC029135, Date: 2022-07-27 Tentative Ruling

Case Number: TC029135    Hearing Date: July 27, 2022    Dept: A

TC029135 CARDOZA, ET AL V. MARTINEZ, ET AL

Wednesday, July 27, 2022, 8:30 A.M.

 

[TENTATIVE] ORDER DENYING PLAINTIFFS’ MOTION FOR SUMMARY ADJUDICATION OF ISSUES AGAINST DEFENDANTS, MARTHA MUNOZ MARTINEZ, JOSE JESUS MARTINEZ, AND ALVINO RODRIGUEZ

 

I.        BACKGROUND AND PROCEDURAL FACTS

The Second Amended Complaint (“SAC”) filed on March 3, 2022, alleges that the residential real property at issue belonged to Plaintiffs’ parents, Jose Munoz (“Father”) and Olivia Munoz (“Mother”) (collectively “Parents”), who subsequently transferred the real property to Plaintiff, Jesus Diaz Munoz, and his sister Andrea Munoz Gonzalez. Defendant, Martha Munoz Martinez (“Martha”), Plaintiffs’ sister, was placed on title in 1995 to facilitate a loan.

            Plaintiffs allege that a July 2005 deed purporting to transfer the property from the Parents to Martha and her husband void because Father’s signature was forged and not notarized.  Plaintiffs allege nine causes of action including claims for: quiet title, fraud, and for cancellation of instruments.

The court originally heard this matter on June 2, 2022 but continued the hearing to allow Defendants controvert Plaintiffs’ forgery allegations with admissible evidence. The court also asked the parties to provide additional briefing addressing whether the claim for forgery required proof of fraudulent intent. The additional briefing is addressed below.         

 

II.      MOTION FOR SUMMARY ADJUDICATION OF ISSUES

A.      Plaintiffs’ Motion filed March 8, 2022

Plaintiffs move to adjudicate the sixth cause of action for cancellation of written instrument against Defendants, Jose Jesus, Martha, and Alvino Rodriguez, (Doe 1) (collectively, “Defendants”). Plaintiffs argue there is no dispute that Father’s signature on the 2005 deed transferring title to Martha and her husband is a forgery. Only Mother’s signature was notarized. The notary’s log does not contain an entry for Father.

            Plaintiffs’ second issue for adjudication seeks a determination of the parties’ interests in the property once the 2005 deed is cancelled. Prior to the 2005 deed, title in the property was held by Mother, Father, Jose Jesus, and Martha all as joint tenants. Mother’s transfer of her one-fourth interest in the property severed the joint tenancy, resulting in Father retaining his one-fourth interest, while Jose Jesus and Martha each held .375 interest. As Father’s interest was not held in a trust, his interest should be probated.

 

B.      Opposition filed May 19, 2022

            Defendants argue that Plaintiffs have not met their initial burden of establishing that Father’s signature is a forgery. Moreover, the SAC is defective because Plaintiffs did not join necessary parties who are seven of the nine Munoz siblings. Whether Father’s signature was forged is a triable issue because the 2005 transfer was made with all the family’s consent. Plaintiff, Pablo Cardoza, (“Pablo”), has not established that he is entitled to contest the 2005 deed since he has not proven that he is Father’s child.

            Defendants contend that the claim for cancellation of the 2005 deed is barred by the statute of limitations. Plaintiffs lack standing to sue because Father and Mother transferred title to Martha in 2005. The second issue to be adjudicated is not a proper issue for adjudication as it does not dispose of the entire cause of action.

            Defendants also ask for a continuance of the hearing to conduct discovery essential to dispute the issue that Father’s signature is a forgery.

 

C.      Supplemental Opposition

Defendants contend that Plaintiffs do not have evidence that Father’s signature was forged. Plaintiffs’ expert did not testify that the signature was forged, rather the expert opined that the signature did not appear to be Father’s.  Martha did not add Father’s signature. She believes the signature on the deed is her Father’s.

The court previously rejected Defendants’ evidence which Defendants ask the court to reconsider. Defendants argue that the parents’ statements indicating their intent to transfer title to Martha and her husband are admissible as statements against their own interests.

To cancel the deed, Plaintiffs must prove that the deed is voidable because of the forgery.  However, Plaintiffs have not proffered evidence to prove it. To establish a forgery, Plaintiffs must provide evidence of a fraudulent intent. Regardless, it is a triable issue of fact since Martha and her siblings attest that the signature is authentic.

The claim for cancellation is subject to the three-year statute of limitations and laches which Defendants raised as an affirmative defense. Plaintiffs did not negate these defenses.

 

  1. Reply filed May 25, 2022

            Plaintiffs argue that Defendants have not produced any admissible evidence to controvert Plaintiffs’ expert declaration establishing that Father’s signature is forged. Rather, Defendants rely on speculation that Father authorized someone else to sign his name. There is no evidence to controvert the fact that only one signature appears in the notary’s journal.

            Plaintiffs argue that the court determined that Plaintiffs’ claims are not barred by the statute of limitations after sustaining Fidelity National Title’s demurrer to the complaint on September 6, 2018. Damages and issues of probate are not relevant to this motion. Plaintiffs argue they are not required to join siblings because who stands to inherit is not the issue. Plaintiff Pablo’s paternity is also not relevant. This is an issue for probate where the court will determine inheritance issues. Plaintiffs argue that Defendants have had four years to conduct discovery since Plaintiffs filed the complaint. All discovery has been completed.

E.      Plaintiffs’ supplemental reply filed on July 15, 2022

Plaintiffs argue that Defendants failed to provide expert testimony to controvert Plaintiffs’ evidence that Father’s signature was forged. The court gave Defendants time to prepare a supplemental opposition in order to obtain expert evidence. Defendants cannot dispute the expert’s declaration with testimony from lay persons. Defendants also do not dispute that Father’s signature is not contained in the notary’s log.

Plaintiffs contend that Defendants’ intent to defraud is established by their conduct once the 2005 deed was recorded. Defendants immediately took out a $51,000 loan secured by the real property because they were having financial distress. Financial gain establishes their intent. Father refused to refinance which is why Defendants forged his name. What Defendants believe Father intended to do is irrelevant.

Defendants are not entitled to reconsideration of the court’s ruling on objections.  This is an improper request. Statements attributed to the parents are inadmissible hearsay. The court has already rejected Defendants’ contention that the claims are barred by the statute of limitations.

 

III.          LEGAL STANDARDS

A party can move for summary adjudication as to one or more causes of action within an action or one or more claims for damages if the party contends that there is no affirmative defense to any cause of action. A motion for summary adjudication shall be granted only if it completely disposes of a cause of action, an affirmative defense, a claim for damages, or an issue of duty. Code Civ. Proc., § 437c(f)(1).

In ruling on the motion, the court considers the material issues defined by the allegations of the complaint. Lewinter v. Genmar Industries, Inc. (1994) 26 Cal.App.4th 1214, 1223. As the moving parties, Plaintiffs’ burden is to prove each element of the claim. If that threshold burden is met, the burden shifts to Defendants to show a triable issue of one or more material facts as to that defense. Code Civ. Proc., §437c(p)(1). The court strictly construes the moving party’s evidence and liberally construes those of the opposing party. All doubts are resolved in favor of the opposing party. Stationers Corp. v. Dun & Bradstreet, Inc. (1965) 62 Cal. 2d 412, 417.

The court applies the three-step analysis to motions for summary judgment/ adjudication: (1) identify the issues framed by the pleading, (2) determine whether the moving party established facts which negate the opponents’ claim, (3) if a defendant meets its threshold burden of persuasion and the burden shifts, determine whether the opposing party has controverted those facts with admissible evidence. Torres v. Reardon (1992) 3 Cal.App.4th 831, 836.

 

IV.    DISCUSSION

  1. Request for Judicial Notice

            The court grants Plaintiffs’ request for judicial notice (“RJN”) of the 2005 Grant Deed, the 2005 Notary Pages, the 1996 Grant Deed, and Father’s death certificate. Evid. Code, § 452(c) [permits judicial notice of official acts of state or federal agencies]. The court also grants judicial notice of a 2004 Deed of Trust and a 2005 Deed of Trust recorded against the property. Plaintiff’s Supp. RJN.

 

 

 

  1. Plaintiffs’ Evidentiary Objections filed May 25, 2022

 

Declarations of Martha, Ruby Munoz Aquirre, and Oscar Munoz.

#1, 3. Sustained. Lacks foundation. Proper parties to an action and the issue of joinder is a question of law.

#2. Sustained. Lacks foundation. Irrelevant. The proper heirs and their potential interests in the real property is a legal question.

#4, 10, 13. Sustained. Speculation, lacks foundation as to what the siblings believed about Plaintiff Pablo’s paternity. Hearsay as to what father said. Irrelevant.

#5, 11 Sustained. Lacks foundation and irrelevant as to the equity in the home and hearsay as to what the Parents conveyed to Martha.

#6, 12 Sustained. Hearsay and irrelevant as to what siblings told Martha.

#7. Sustained. Lacks foundation as to what other people allegedly knew about the 2005 transfer.

#8, #14. Sustained. Speculation, lacks foundation, hearsay, as to what Father authorized.

#9. Sustained. Lacks foundation and hearsay as to what Plaintiffs “reasonably should have known” about the 2005 transfer of title based on “discussion” with family members.

The court denies Defendants’ request to reconsider these objections. The court also declines to consider the new declarations of Martha, Ruby, and Oscar, filed on June 30, 2022, since the court limited new evidence to submittal of Defendants’ expert declaration, which was not submitted.

           

  1. Issue 1: Whether the 2005 Deed is void and should be cancelled pursuant to the sixth cause of action.

 

An “instrument” is a “written paper signed by a person or persons transferring the title to, or giving a lien on real property, or giving a right to a debt or duty. (Gov. Code § 27279.)” Bank of America v. Greenbach (1950) 98 Cal.App.2d 220.  A written instrument may be cancelled if there is a reasonable apprehension that if left outstanding, it may cause serious injury to a person against whom it is void or voidable. Civ. Code, § 3412. Cancellation is essentially a request for rescission that places the parties where they were before the instrument was made. Deutsche Bank National Trust Co. v. Pyle (2017) 13 Cal.App.5th 513, 523.

            A deed is “void” if "the grantor's signature is forged or if the grantor is unaware of the nature of what he or she is signing." Schiavon v. Arnaudo Brothers (2000) 84 Cal.App.4th 374, 378. A “forgery” is defined as “a writing which falsely purports to be the writing of another and is executed with the intent to defraud." Id. at 382. Accordingly, intent to defraud is an element of forgery. People v. Franco (2018) 6 Cal.5th 433, 439 [“Forgery, at common law, is the false making or materially altering, with intent to defraud, of any writing which, if genuine, might apparently be of legal efficacy, or the foundation of a legal liability.”]. Forged or altered deeds are void instruments and “cannot ordinarily provide the foundation for good title even in the hands of an innocent purchaser, as where a deed has been forged or has not been delivered.” Firato v. Tuttle (1957) 48 Cal.2d 136, 139.

            Plaintiffs have not met their burden of establishing that the 2005 deed was forged to include Father’s signature without his consent. Plaintiffs have not proffered material facts to establish Martha’s intent to defraud, which is a necessary element. In Plaintiffs’ supplemental reply, Plaintiffs concede that intent to defraud is a necessary element of the claim; Plaintiffs argue that Martha’s intent is reflected by her motivation for financial gain. Supp. Reply 4:3 – 4:3. Plaintiffs were not permitted to correct their prior failure to establish intent by adding this additional evidence to supplement their initial separate statement. The court continued the hearing to establish whether intent was a necessary element of forgery, and to permit Defendants to controvert Plaintiffs’ expert declaration. Defendants did not proffer any expert evidence with their supplemental opposition. However, that failure does not warrant granting the motion since Plaintiffs did not meet their initial burden of establishing intent to defraud.

To reiterate, Plaintiffs attempt to establish forgery with three material facts: That Father did not sign the 2005 deed (UF 1), that Father’s signature does not appear in the notary’s official records (UF 2), and only one signature was notarized (UF 3). Plaintiffs submit the recorded 2005 deed bearing Father’s signature and the official journal of the notary reflecting that only Mother’s signature was notarized. Both records are public records certified by the Los Angeles County Recorder.

            Without any material facts establishing fraudulent intent, the court cannot adjudicate the sixth cause of action for cancellation of instruments. Even if the court were to consider the additional evidence of financial gain submitted with Plaintiffs’ supplemental reply, Martha declares that her motivation for taking ownership of the property was to save the house from foreclosure. Declaration of Martha Munoz, ¶ 6. She declares that both parents signed the deed transferring the property to her. Id. ¶ 7. Therefore, the intent element is a triable issue of fact.

 

  1. Issue 2: Effect of the cancellation.

 

Although the first tentative ruling was not adopted by the court, the supplemental briefing does not affect the court’s determination that the effect of cancellation cannot be summarily adjudicated.  As previously stated, a motion for summary adjudication shall be granted only if it completely disposes of a cause of action, an affirmative defense, a claim for damages, or an issue of duty. Code Civ. Proc., § 437c(f)(1). What Plaintiffs seek is declaratory 00relief, which was not raised in the moving papers.

            Plaintiffs alleged a ninth cause of action for declaratory relief, however, the remedy sought is to return title to Father, and a declaration that Plaintiffs’ interests supersede that of Wilmington (holder of the first trust deed), which is not what Plaintiffs seek in Issue 2 for adjudication. Issues which are material to a motion for summary adjudication are determined by the complaint.  Lewinter v. Genmar Industries, Inc. (1994) 26 Cal.App.4th 1214, 1223.

            Defendants’ procedural arguments with respect to joinder of necessary parties, standing to sue, and Pablo’s paternity are irrelevant to the issues raised by Plaintiffs in their sixth cause of action. Therefore, the court does not address these issues. Since Plaintiffs did not meet their initial burden, the court does not determine whether a continuance of the hearing is warranted.

            Lastly, Plaintiffs’ supplemental reply contends that the defense of the statute of limitations “has already been ruled upon by this Court and said ruling is res judicata and cannot be revisited here.” Supp. Reply, 5:23-24. While Judge Long previously did not consider Defendants’ argument regarding the statute of limitations, upon further consideration, the defense is material to this motion. Plaintiffs cite to the Hon. Maurice Leiter’s ruling of September 16, 2018, sustaining Fidelity National Title Company’s demurrer to the complaint. See Min. Ord. 9/16/18. That demurrer related to a prior version of the pleading. It has been superseded by the filing of the SAC on 3/3/22. Fireman's Fund Ins. Co. v. Sparks Construction, Inc. (2004) 114 Cal. App. 4th 1135, 1144. [“It is well established that an amendatory pleading supersedes the original one, which ceases to perform any function as a pleading.”].

            The court’s docket also reflects that on September 10, 2019, the Hon. Gary Tanaka heard and denied Plaintiffs’ Motion for Summary Judgment or Adjudication of the First Amended Complaint. Judge Tanaka denied the motion in part because Plaintiffs failed to negate the statute of limitations defense. Min. Ord. 9/10/19, page 3, subpart (c).

            Ordinarily, it is not the plaintiff’s initial burden to disprove affirmative defenses asserted by defendant. Code Civ. Proc., § 437c(p(1). Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 853 ["For example, summary judgment law in this state no longer requires a plaintiff moving for summary judgment to disprove any defense asserted by the defendant as well as prove each element of his own cause of action."]. A proper function of the reply is to respond to the opposing party’s statement of additional disputed facts by demonstrating why these additional facts do not undermine the material facts set forth in the moving papers. Weil & Brown, Cal. Practice Guide: Civil Procedure Before Trial (The Rutter Group 2022) § 10:220.5. However, if defendant raises the statute of limitations defense in its opposition, the moving party must address this issue with additional responsive evidentiary facts in the reply. Id., § 10:235.

            Defendants argued in opposition that Plaintiffs knew about the 2005 deed for the past 17 years, therefore, their claims are barred by laches and the statute of limitations. Opp. 18:2-9. Additionally, Defendants asserted the statute of limitations as the 15th affirmative defense and laches as the 19th affirmative defense. Answer filed 4/5/22, 9:19-22, 10:14-18.

The applicable statute of limitations for a particular claim depends on the nature of the cause of action i.e., the gravamen of the action. Hensler v. City of Glendale (1994) 8 Cal.4th 1, 22. The claim for cancellation is based on a forgery, “a species of fraud,” which is governed by the three-year statute of limitations. O'Bryan v. Superior Court of Los Angeles County (1941) 18 Cal.2d 490, 497. The claim does not accrue until the discovery of the facts constituting the fraud or mistake. Code Civ. Proc., § 338(d). Plaintiffs’ failure to persuasively address this issue negating the defense is a separate ground for denial of the motion.

 

V.                  CONCLUSION

            As Plaintiffs have not met their threshold burden, the burden does not shift to Defendants to show a triable issue of one or more material facts as to that claim. Code Civ. Proc., §437c(p)(1). Therefore, the motion is DENIED.