Zamora v. Bagatsing
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a 439-square-meter parcel of land in Pasay City, originally registered under the names of spouses Rosita and Jesus Zamora. The Bagatsings claim that the spouses Zamora donated this property to Zenaida Lazaro, the mother of the Bagatsings and aunt of Rosita, via a notarized Deed of Donation dated May 31, 1991. This donation allegedly led to the issuance of a new title in Lazaro's name. Rosita, however, contends that she and her husband mortgaged the property and that Lazaro offered to pay the loan to redeem it, for which she provided the owner's duplicate copy of the title. Rosita later discovered that the title had been cancelled and reissued in Lazaro's name. 2. Procedural History: Approximately 24 years after the alleged donation, Rosita filed an Affidavit of Adverse Claim on the title in Lazaro's name, asserting forgery of her and her deceased husband's signatures on the Deed of Donation. This resulted in an annotation of the adverse claim. Subsequently, Lazaro executed a Deed of Sale in favor of her children, the Bagatsings, who registered the property under their names, with the adverse claim annotation persisting. The Bagatsings then filed a petition with the Regional Trial Court (RTC) of Pasay City, Branch 118, seeking the cancellation of this adverse claim annotation. The RTC denied the petition, finding the Deed of Donation to be a forgery. The Bagatsings appealed to the Court of Appeals (CA), which reversed the RTC's decision, cancelled the adverse claim, and ruled that Rosita's claim was barred by prescription and laches, despite acknowledging the forged signatures. Rosita's motion for reconsideration was denied, leading to the present petition. 3. The Petition: This case is before the Supreme Court via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. Rosita argues that the Court of Appeals erred in ruling on prescription and laches in a land registration case and, more importantly, in holding that an action based on a forged instrument had prescribed. Rosita contends that a forged deed is a nullity and conveys no title, rendering any subsequent transactions void and any action for reconveyance based on such nullity imprescriptible. She asserts that the RTC correctly found the Deed of Donation to be forged and therefore correctly denied the Bagatsings' petition to cancel the adverse claim.
Issue(s)
Whether or not the Court of Appeals committed an error in law when it tackled matters relating to prescription of an action for reconveyance in an appealed land registration case, specifically concerning the propriety of discussing prescription and the nature of the original action. Whether or not the Court of Appeals committed an error in law when it ruled that the action for reconveyance based on an instrument whose execution was forged had prescribed, considering the imprescriptibility of actions based on void conveyances.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision and resolution of the Court of Appeals, and reinstated the decision of the Regional Trial Court dismissing the petition for cancellation of annotation of adverse claim.
Ratio Decidendi
On the first issue: The Court ruled that the Court of Appeals did not commit an error in law when it tackled matters relating to prescription of an action for reconveyance in an appealed land registration case because the issue of the Statute of Limitations was raised by the respondents (Bagatsings) in their Appellants' Brief before the CA. However, the Court clarified that it was erroneous for the CA to rule on the basis of prescription of an action for reconveyance, as the original action was a petition for cancellation of annotation of adverse claim, not an action for reconveyance. The Court emphasized the distinct purposes and nature of an action for reconveyance and an annotation of adverse claim. On the second issue: The Court ruled that the Court of Appeals committed an error in law when it ruled that the action for reconveyance based on a forged instrument had prescribed. The Court reiterated that the appealed case was about the cancellation of an adverse claim, not an action for reconveyance. Nevertheless, assuming arguendo that it was an action for reconveyance, the Court found that it had not prescribed. Citing Heirs of Arao v. Heirs of Eclipse, the Court held that a complaint for cancellation of title based on the nullity of a Deed of Conveyance does not prescribe, and an action predicated on a conveyance that is null and void ab initio is imprescriptible. Because the signatures of the spouses Zamora on the Deed of Donation were forged, rendering the deed and subsequent transactions null and void, an action for reconveyance based on these null and void conveyances is imprescriptible, and laches cannot be set up against such a right.
Main Doctrine
An action for reconveyance based on a forged instrument is imprescriptible, and laches cannot be invoked against such a claim. Furthermore, a petition for cancellation of an annotation of adverse claim is distinct from an action for reconveyance, and the prescriptive periods applicable to the latter do not automatically apply to the former.