Heirs of Bagaygay v. Heirs of Paciente
REITERATIONFacts
The Antecedents: Anastacio Paciente, Sr. was granted a homestead patent over a parcel of land, and an Original Certificate of Title (OCT) No. V-2423 was issued in his name. Allegedly, Anastacio executed a Deed of Sale in favor of his brother-in-law, Eliseo Bagaygay, who took possession, transferred the title to his name, and subdivided the land into three lots under Transfer Certificates of Title (TCT) Nos. T-34610, T-34611, and T-34612. Anastacio died in 1989, and Eliseo died in 1991. Eliseo's heirs took possession of the land. Procedural History: In 1999, the heirs of Anastacio filed an action for Declaration of Nullity of the Deed of Sale and titles, Recovery of Ownership and Possession, Accounting, and Damages against the heirs of Eliseo. They alleged that Eliseo obtained the title and possession by taking advantage of Anastacio's financial distress, that Anastacio never sold the land, and that the Deed of Sale was void for being executed within the five-year prohibitory period under Section 118 of the Public Land Act. The heirs of Eliseo moved to dismiss, which was denied. They filed an Answer, arguing valid purchase and raising prescription and laches. The Regional Trial Court (RTC) dismissed the complaint and counterclaims, giving credence to the testimonies that the sale occurred in 1958, beyond the prohibitory period. The Court of Appeals (CA) reversed the RTC, giving more weight to the documentary evidence (Primary Entry Book) which indicated the Deed of Sale was executed on November 28, 1956, within the prohibitory period, thus declaring the sale void ab initio and ordering the return of the land, subject to reimbursement of the purchase price and the government's right to institute reversion proceedings. The CA denied the motion for reconsideration. The Petition: The heirs of Eliseo (petitioners) filed a Petition for Review on Certiorari, assailing the CA's decision and resolution. They argued that the CA erred in not giving weight to the RTC's factual findings that the Deed of Sale was executed in 1958, based on testimonial evidence, and in overlooking the marriage of respondent Meregildo Paciente in 1958 as the reason for the sale. They also contended that the CA erred in not applying the principle of laches, given the 44-year delay in filing the case after the original parties were deceased.
Issue(s)
Whether the Court of Appeals erred in giving more weight to the documentary evidence (Primary Entry Book) over the testimonial evidence regarding the date of execution of the Deed of Sale. Whether the Court of Appeals erred in not applying the principle of laches in favor of the petitioners. Whether the Deed of Sale is void ab initio for having been executed within the five-year prohibitory period under Section 118 of Commonwealth Act No. 141.
Ruling
The Supreme Court denied the petition for lack of merit, affirming the decision of the Court of Appeals. The Court held that documentary evidence prevails over testimonial evidence, that laches does not apply to void ab initio contracts, and that the Deed of Sale was void ab initio as it was executed within the five-year prohibitory period.
Ratio Decidendi
On the issue of documentary vs. testimonial evidence: The Court reiterated the rule that documentary evidence generally prevails over testimonial evidence, as the latter can be easily fabricated and human memory regarding dates can be frail. In this case, the Primary Entry Book of the Register of Deeds, being an official record, is considered prima facie evidence of the facts stated therein. The testimonies presented by the petitioners regarding the date of sale (1958) were found unreliable due to the witnesses' age and inability to recall personal details, and lacked material corroboration. The Court found no sufficient evidence presented by the petitioners to overcome the presumption of truth accorded to the official record in the Primary Entry Book, which indicated the Deed of Sale was executed on November 28, 1956. On the issue of laches: The Court held that the principle of laches does not apply to contracts that are void ab initio. The action or defense for the declaration of the inexistence of a contract does not prescribe. The Court emphasized that equity, which forms the basis of laches, should not prevail over a positive statutory mandate, such as the imprescriptibility of actions to declare a contract void. Since the Deed of Sale was found to be void from the beginning due to violation of the Public Land Act, the defense of laches could not be invoked to resist the enforcement of the legal right to recover the property. On the validity of the Deed of Sale and the prohibitory period: The Court affirmed the CA's finding that the Deed of Sale was void ab initio because it was executed on November 28, 1956, which falls within the five-year prohibitory period from the issuance of the homestead patent on October 24, 1953, as mandated by Section 118 of Commonwealth Act No. 141. The sale of land acquired under free patent or homestead provisions within this period is explicitly prohibited and renders the sale null and void. Consequently, the property should be returned to the heirs of Anastacio, subject to the government's right to institute reversion proceedings, and the heirs of Eliseo are to be reimbursed the purchase price, with improvements and interest compensated by the fruits received from possession.
Main Doctrine
Documentary evidence, particularly official records like the Primary Entry Book of the Register of Deeds, generally prevails over testimonial evidence, especially when the latter is unreliable due to age or lack of corroboration. Contracts void ab initio, such as those violating statutory prohibitions like the five-year alienation period for homestead patents, are imprescriptible and not subject to the defense of laches.