G.R. No. 190995 . August 09, 2017.
BENJAMIN A. KO, ET AL., PETITIONERS, V. VIRGINIA DY ARAMBURO, ET AL., RESPONDENTS.

FACTS

Respondents, led by Virginia Dy Aramburo, filed a complaint for recovery of ownership and/or reconveyance against Corazon Aramburo Ko. The dispute involved seven parcels of land in Tabaco City, Albay, all registered under Corazon’s name. Respondents alleged that the properties were originally acquired in 1970 by the spouses Simeon (Virginia’s husband) and Corazon (Simeon’s sister) from their relatives. They claimed a one-third pro-indiviso share for Virginia and another one-third for the heirs of their deceased brother, Augusto Aramburo, leaving Corazon with the remaining third. They asserted that Corazon used falsified documents to consolidate full ownership.
Corazon, and later her heirs (the petitioners), countered that the properties were ceded only to her and Simeon. She claimed Simeon later sold his entire one-half share to her through a Deed of Absolute Sale dated December 14, 1974, making her the sole owner. She also argued that a prior Deed of Cession granting a share to Augusto’s heirs was recalled and never implemented. Corazon further contended that the action was barred by prescription.

ISSUE

The core issue was whether the December 14, 1974 Deed of Absolute Sale, wherein Simeon purportedly sold his share to Corazon, was valid, thereby making Corazon the exclusive owner of the disputed properties.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ rulings, declaring respondents as co-owners. The Court upheld the finding that Virginia’s signature on the 1974 Deed of Sale was a forgery, as conclusively established by the National Bureau of Investigation. This finding was factual and binding, as no compelling reason was shown to overturn it.
The legal consequence was fatal to the petitioners’ claim. Under the governing law at the time, the Civil Code provisions on conjugal partnership, a husband could not alienate or encumber any real property of the conjugal partnership without the wife’s consent. The subject properties, acquired during Simeon and Virginia’s marriage, were presumed conjugal. The forged sale, lacking Virginia’s valid consent, was therefore void. A void contract produces no legal effect and cannot transfer ownership. Since the sale was void ab initio, Simeon’s one-half share remained part of the conjugal partnership, and upon his death, passed to his compulsory heirs, including Virginia. Consequently, Corazon did not become the sole owner. The Court also found no merit in the defense of prescription, as an action to declare a void contract inexistent does not prescribe. Thus, respondents rightfully sought the reconveyance of their one-third shares in the properties.