Cotoner-Zacarias v. Revilla
REITERATIONFacts
The Antecedents: Spouses Alfredo and Paz Revilla owned a 15,000-square-meter unregistered parcel of land. Facing financial difficulties, Paz borrowed money from Amada Cotoner-Zacarias, verbally agreeing that Amada would take possession of the property, cultivate it, and use the earnings to pay the loan and taxes, after which the property would be returned. Unknown to the Revilla spouses, Amada presented a fictitious "Kasulatan ng Bilihan ng Lupa" (Deed of Sale of Land) dated March 19, 1979, with the Revilla spouses as sellers and Amada as buyer. This led to the cancellation of the tax declaration in the Revilla spouses' name and the issuance of a new one in Amada's name. Amada subsequently sold the property to spouses Adolfo and Elvira Casorla, who then sold it to spouses Rodolfo and Yolanda Sun. Procedural History: Upon Alfredo Revilla's return from Saudi Arabia in December 1994, he discovered the property's tax declaration was in the Sun spouses' name. In February 1995, the Revilla spouses saw a copy of the "Kasulatan ng Bilihan ng Lupa" and realized their signatures were forged. They demanded cancellation of the sale and transfers, and reconveyance of the property. When Amada failed to act, the Revilla spouses filed a complaint for annulment of sales and transfers, reconveyance, and damages against Amada and the subsequent buyers. The Regional Trial Court (RTC) declared the "Kasulatan ng Bilihan ng Lupa" fictitious and ruled in favor of the Revilla spouses, ordering the annulment of sales/transfers and awarding damages. Amada appealed, and the Sun spouses partially appealed. The Court of Appeals (CA) dismissed Amada's appeal and partially granted the Sun spouses' appeal, modifying the damages. Amada's motion for reconsideration was denied, leading to the present petition. The Petition: Amada Cotoner-Zacarias petitions the Supreme Court, arguing that the alleged antichresis agreement was void for not being in writing. She claims the sale in her favor was established by the "Kasulatan ng Bilihan ng Lupa" and witness testimony. She also contends the lower courts erred in placing the burden of proof of forgery on her and that the Revilla spouses' action had prescribed. Furthermore, she questions the docket fees paid and argues that the sale of Paz Castillo-Revilla's half-share cannot be declared void, and the Sun spouses were buyers in good faith.
Issue(s)
Whether the Revilla spouses' cause of action is barred by prescription or laches. Whether the trial court acquired jurisdiction considering the docket fees paid based on the claimed damages versus the alleged property value. Whether the Court of Appeals erred in upholding the reinstatement and reconveyance of the property in favor of the Revilla spouses.
Ruling
The petition is DENIED for lack of merit. The decision of the Court of Appeals dated August 13, 2009, is AFFIRMED.
Ratio Decidendi
On the issue of prescription or laches: The Court held that the Revilla spouses' cause of action is not barred by prescription or laches. The elements of laches were not met, as the Revilla spouses filed their complaint within nine months of discovering the fraudulent transfers. More importantly, the Court reiterated that actions for the declaration of the inexistence of a contract are imprescriptible under Article 1410 of the Civil Code. Doctrines of equity like laches cannot prevail against a clear statutory mandate. Therefore, the Revilla spouses' right to seek the annulment of the fictitious sale, despite the lapse of time, is legally protected. On the issue of jurisdiction and docket fees: The Court found that the trial court acquired jurisdiction because the Revilla spouses paid the proper docket fees. The complaint explicitly prayed for actual damages of ₱50,000.00, and this amount, not the ₱12,000,000.00 mentioned during pre-trial, formed the basis for the docket fees. The Court emphasized that the jurisdiction of the court is determined by the nature of the action pleaded in the complaint and the relief sought therein. Since the complaint was not formally amended to increase the claimed damages, the trial court correctly proceeded based on the amounts stated in the original prayer. On the issue of reinstatement and reconveyance: The Court affirmed the lower courts' order of reinstatement and reconveyance. This was primarily based on the finding that the "Kasulatan ng Bilihan ng Lupa" was a forged document, rendering the sale void ab initio. The Court gave weight to the findings of the lower courts, including the NBI's report on the forged signature of Alfredo Revilla. Even if Paz Castillo-Revilla's signature was not forged, the sale would still be void as to her share because it was executed without her husband's consent, violating Article 172 of the Civil Code (applicable at the time of the transaction). The argument regarding the Sun spouses being buyers in good faith was deemed a personal defense not attributable to the petitioner, and moreover, it involved unregistered land where purchasers buy at their own peril.
Main Doctrine
Conveyances by virtue of a forged signature are void ab initio. The absence of essential requisites of consent and cause or consideration renders the contract inexistent. Actions for the declaration of the inexistence of a contract are imprescriptible. The payment of proper docket fees is crucial in vesting courts with jurisdiction over the subject matter.