G.R. No. 151016 ; August 6, 2008
SPOUSES SOFRONIO SANTOS and NATIVIDAD SANTOS, FROILAN SANTOS, CECILIA M. MACASPAC, and R TRANSPORT CORPORATION, petitioners, vs. HEIRS OF DOMINGA LUSTRE, namely TARCISIO MANIQUIZ, TERESITA BURGOS, FLORITA M. REYES and LERMIE MANIQUIZ, respondents.

FACTS

Dominga Lustre owned a lot in Nueva Ecija. In 1974, she mortgaged it to Spouses Santos. In 1976, a Deed of Absolute Sale purportedly conveyed the property to Natividad Santos, leading to the issuance of a new title in the spouses’ names. They later sold it to their son, Froilan Santos. In 1994, some heirs of Dominga Lustre, including petitioner Cecilia Macaspac, filed an action (Civil Case No. 1330) against Froilan, seeking to declare the 1984 sale inexistent and for reconveyance. This case was referred to the municipal trial court due to jurisdictional value.
While Civil Case No. 1330 was pending, other heirs of Dominga Lustre (the respondents) filed a new complaint in 1999 (Civil Case No. 2115) against the Santos spouses, Froilan, Cecilia Macaspac (who refused to join as plaintiff), and others. This action sought the annulment of the 1976 Deed of Sale and the resulting titles, alleging forgery and simulation of the contract. The petitioners moved to dismiss this second case, arguing prescription and laches.

ISSUE

Whether the Court of Appeals erred in denying the Motion to Dismiss Civil Case No. 2115 on the grounds of prescription, laches, and lis pendens.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The grounds for dismissal raised by petitioners were not indubitable. On prescription, an action for annulment of a void contract does not prescribe. The respondents’ complaint alleged the Deed of Sale was simulated and forged, rendering it void ab initio. A void contract produces no legal effect, and the right to seek its declaration of nullity is imprescriptible. The defense of laches likewise fails at this preliminary stage. Laches is not concerned with the mere passage of time but with the inequity of permitting a claim due to a party’s neglect. The factual allegations—that respondents have continuously resided on the property and only discovered the fraud upon the filing of an ejectment suit—must be proven in a full trial to determine if laches applies.
Furthermore, the rule on lis pendens was not violated. For lis pendens to warrant dismissal, the pending prior action must involve the same parties, the same rights, and the same reliefs. Here, the parties were not identical, as the plaintiffs in the two cases were different sets of heirs, and Cecilia Macaspac was a plaintiff in the first case but a defendant in the second. The causes of action also differed: the first case (filed in 1994) sought annulment based on a simulated 1984 sale, while the second case (filed in 1999) attacked a forged 1976 deed. The reliefs, though similar, stemmed from distinct factual allegations. Therefore, a trial on the merits was necessary to resolve the substantive issues.