Uy v. Naval-Sai
REITERATIONFacts
The Antecedents: Carmencita Naval-Sai (Naval-Sai) acquired ownership of two lots, Lot No. 54-B-8 and Lot No. 54-B-9. She sold one lot to Bobby Adil on installment, who later sold his unfinished building to spouses Francisco and Louella Omandac due to non-payment. Naval-Sai delivered the titles of the two lots to Grace Ng as security for a loan. Ng, in turn, delivered these titles to petitioner Aniceto Uy as security for her own loan from Uy. Subsequently, Uy filed a case for recovery of possession against Francisco Omandac, which Uy won, leading to the ejection of the Omandacs. Naval-Sai later learned of this case and claimed her signature on a purported deed of sale to Uy was forged. Procedural History: Naval-Sai filed a Complaint for Annulment of Deed with Damages against Uy, alleging the deed of sale for the two lots was a forgery and her signature was spurious. She later amended the complaint to include a prayer for the declaration of nullity of the new Transfer Certificates of Title (TCTs) issued in Uy's name. The Regional Trial Court (RTC) dismissed the complaint on grounds of prescription and a defective certification against forum shopping, ruling that the action was a collateral attack on the titles and that the one-year period for challenging titles had lapsed. The Court of Appeals (CA) set aside the RTC's order, finding substantial compliance with the certification against forum shopping and ruling that the action was one for reconveyance based on a void contract, which is imprescriptible. The CA remanded the case for further proceedings. Uy's motion for reconsideration was denied. The Petition: Uy filed a Petition for Review on Certiorari, assailing the CA's ruling on substantial compliance with the certification against forum shopping and its finding that the action has not prescribed and that Naval-Sai is not guilty of laches or estoppel.
Issue(s)
Whether there was substantial compliance with the requirements on certification against forum shopping. Whether the action for annulment of deed and reconveyance has prescribed or if the respondent is guilty of laches or estoppel.
Ruling
The petition is denied. The case is remanded to the Regional Trial Court for further proceedings to determine the issue of forgery and the merits of the case.
Ratio Decidendi
On the issue of substantial compliance with the certification against forum shopping: The Court held that there was substantial compliance. While the amended complaint's certification was signed by counsel and not by Naval-Sai, the original complaint had a proper certification signed by Naval-Sai. The CA considered the amended certification's statement to be read with the original as a "cautionary move" amounting to substantial compliance. Although an amended complaint supersedes the original, the Court found that the prima facie merits of the case served as a special circumstance or compelling reason to relax the rules, citing previous cases where procedural lapses were overlooked in the interest of substantial justice. The Court reiterated that procedural rules should not be used to derail justice but to achieve it expeditiously. On the issue of prescription and laches: The Court agreed with the CA that the nature of Naval-Sai's action is one for reconveyance based on a void contract, which is imprescriptible. The Court clarified that while an action for reconveyance based on implied trust or fraud generally prescribes in ten years, an action based on a void contract, where consent is entirely absent (as in forgery), is imprescriptible. The issuance of a certificate of title does not validate a void purchase. The Court noted that both the RTC and CA failed to make definitive findings on the alleged forgery, as the RTC dismissed the case based on pleadings and the CA resolved it on available records to avoid delay. Therefore, the dismissal on grounds of prescription and laches was premature. The Court emphasized that summary dismissal is improper when factual matters requiring evidence are in dispute. If the trial court finds the deed of sale to be forged, the action for reconveyance will be imprescriptible. If not, the sale will stand. Similarly, laches, being evidentiary, cannot be established by mere allegations in pleadings and its dismissal at this stage would be premature.
Main Doctrine
An action for reconveyance based on a void contract, such as a forged deed of sale, is imprescriptible. However, the determination of whether the deed of sale is forged requires a full-blown trial, and dismissal based on prescription or laches is premature without such determination.