Viovicente v. Viovicente
REITERATIONFacts
1. The Antecedents: Petitioners, Spouses Teodorico and Dominga Viovicente, alleged that their son, Danilo, coerced them into signing a Deed of Absolute Sale for their property on June 24, 1993, without receiving any payment. They further claimed that Danilo later used a falsified Deed of Absolute Sale dated December 14, 1995, to transfer the property to himself and his wife, Alice. The petitioners initiated a complaint for reconveyance of property and nullity of sale, asserting that both deeds were either signed under duress or forged, and that no consideration was ever received. 2. Procedural History: The Regional Trial Court (RTC) initially ruled in favor of the petitioners, declaring the Deed of Absolute Sale dated June 24, 1993, null and void for lack of consideration and ordering the reconveyance of the property. However, the Court of Appeals reversed this decision, finding that the cancellation of the title was based on the December 14, 1995 deed, which the petitioners failed to prove was forged. The appellate court also ruled that the action for reconveyance had prescribed. The petitioners' motion for reconsideration was denied by the Court of Appeals. 3. The Petition: Before the Supreme Court, the petitioners seek to reverse the Court of Appeals' decision. They argue that there was only one deed signed under duress without consideration, and the December 14, 1995 deed was a forgery with altered entries. They contend that the Court of Appeals erred in presuming the validity of the notarized deed and the Torrens title, as the deed was not formally offered and contained alterations. Furthermore, they assert that their action for reconveyance based on fraud and nullity of contract is imprescriptible, contrary to the appellate court's ruling that it had prescribed. The core of their petition is that both deeds are void, rendering the subsequent title invalid.
Issue(s)
Whether petitioners' causes of action are barred by prescription. Whether there was a valid conveyance of the subject property in favor of respondents.
Ruling
The petition is meritorious. The Decision dated May 20, 2014 and Resolution dated June 18, 2015 of the Court of Appeals are REVERSED and the Regional Trial Court's Amended Decision dated July 16, 2010 is REINSTATED. WHEREFORE, judgment is hereby rendered in favor of plaintiffs and against defendants hereby directing defendants to reconvey to plaintiffs the property originally covered by Transfer Certificate of Title T-356656; declaring the Deed of Absolute Sale dated June 24, 1993 as null and void; and directing the Register of Deeds of Calamba, Laguna to cancel Transfer Certificate of Title T-356656 issued in the name of defendant Danilo L. Viovicente and to issue a new Transfer Certificate of Title in the name of plaintiff Teodorico M. Viovicente, married to Dominga L. Viovicente.
Ratio Decidendi
On the issue of prescription: The Supreme Court held that petitioners' action for reconveyance based on a void deed of sale is imprescriptible. The Court clarified that an action for the declaration of the inexistence of a contract, such as a simulated or void deed of sale, does not prescribe under Article 1410 of the Civil Code. The Court distinguished this from actions based on fraud, which must be filed within four years from discovery. In this case, the allegations in the complaint clearly pointed to a void deed of sale due to lack of consideration and forgery, not merely fraud. On the issue of valid conveyance: The Supreme Court ruled that there was no valid conveyance of the property. The Deed of Absolute Sale dated December 14, 1995, was found to be spurious and forged. Evidence showed that the "5" in "1995" was superimposed on a "3," indicating the deed was originally dated June 24, 1993, and later altered. Furthermore, respondents admitted that this deed was unilaterally executed by Phio, Danilo's brother, to avoid surcharges, not by the owners. The Deed of Absolute Sale dated June 24, 1993, was also declared void for lack of consideration, as petitioners testified they were coerced into signing it and received no payment. The Court reiterated that a contract of sale requires consent, a determinate subject matter, and a price certain in money or its equivalent, and absent any of these, the sale is void. The Court cited Article 1471 of the Civil Code, stating that if the price is simulated, the sale is void.
Main Doctrine
A forged or spurious Deed of Absolute Sale is void and cannot be the source of ownership. Consequently, a Transfer Certificate of Title (TCT) issued based on such a void deed is also void. An action for the declaration of the inexistence of a contract, such as a void deed of sale, does not prescribe.