G.R. No. 213001, August 04, 2021
LAURO CARDINEZ, ISIDRO CARDINEZ, JESUS CARDINEZ, VIRGIE CARDINEZ, FLORA LACONSAY AND AIDA DELA CRUZ, PETITIONERS, VS. SPOUSES PRUDENCIO AND CRESENCIA CARDINEZ, RESPONDENTS.

FACTS

The late Simeona Cardinez owned a parcel of land inherited by her sons Prudencio, Florentino, and Valentin. In 1994, Valentin requested Prudencio and his wife Cresencia to sign a document, representing it as necessary for the partition of their inherited land and the transfer of their shares. Trusting Valentin, the spouses, who had limited education, signed the English document without reading or understanding it. They were not given a copy. Fourteen years later, in 2008, Prudencio discovered that the document was a Deed of Donation dated April 26, 1994, purportedly donating his share to Valentin’s children (the petitioners). The donation was notarized, and a new title (TCT No. T-40459) was issued in the petitioners’ names. The respondents filed a complaint for annulment of the document, alleging fraud and misrepresentation. The petitioners claimed the donation was valid and that the action had prescribed.

ISSUE

Whether the Deed of Donation is valid and whether the action to annul it has prescribed.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The Deed of Donation was declared null and void ab initio. The consent of the respondents was vitiated by fraud, as they were deceived into signing a donation document under the false pretense that it was for partition. Fraud invalidates consent, a requisite element of a valid donation. Consequently, the donation is void from the beginning, not merely voidable. A void contract produces no effect and can be attacked at any time; thus, the action has not prescribed. The Court also upheld the right to reconveyance, as the property was wrongfully registered under the Torrens system.