GR 219074; (July, 2020) (Digest)
G.R. No. 219074 , July 28, 2020
SPOUSES TEODORICO M. VIOVICENTE AND DOMINGA L. VIOVICENTE, PETITIONERS, VS. SPOUSES DANILO L. VIOVICENTE AND ALICE H. VIOVICENTE, THE REGISTER OF DEEDS OF CALAMBA, LAGUNA, RESPONDENTS.
FACTS
Petitioners Spouses Teodorico and Dominga Viovicente are the registered owners of a property in San Pedro, Laguna, covered by TCT No. T-264547, acquired through a GSIS loan. They alleged that on June 24, 1993, their son, respondent Danilo Viovicente, forced them through intimidation and violence to sign a Deed of Absolute Sale without any consideration. They later discovered that a second Deed of Absolute Sale dated December 14, 1995, which they denied executing, was used to transfer the property to respondents, resulting in the issuance of TCT No. T-356656. Petitioners filed a complaint for reconveyance and nullity of sale in 2003, asserting that the deeds were spurious, lacked consideration, and were executed through fraud. Respondents claimed there was a valid agreement for the sale and denied coercion. The trial court ruled in favor of petitioners, declaring the June 24, 1993 deed null and void and ordering reconveyance. The Court of Appeals reversed, dismissing the complaint on grounds of prescription and upholding the validity of the December 14, 1995 deed as a notarized document.
ISSUE
1. Whether petitioners’ action for reconveyance based on a null deed of sale had prescribed.
2. Whether there was a valid conveyance of the property to respondents.
RULING
The Supreme Court granted the petition, reversed the Court of Appeals, and reinstated the trial court’s decision.
1. On Prescription: The action for reconveyance based on a void or inexistent contract is imprescriptible. Petitioners’ complaint alleged that the Deed of Absolute Sale was void due to lack of consideration and was spurious. An action to declare a void contract inexistent does not prescribe. The Court of Appeals erred in applying the four-year prescriptive period for reconveyance based on fraud, as the deed was fundamentally void.
2. On Validity of Conveyance: The purported sale was invalid. The Deed of Absolute Sale dated June 24, 1993, was executed without consideration, rendering it void under Article 1471 of the Civil Code. Petitioners’ testimonies of coercion were credible and corroborated. The Deed of Absolute Sale dated December 14, 1995, was found to be a falsified version of the 1993 deed, with alterations (e.g., the year “1995” superimposed over “1993”) as confirmed by an NBI document examiner. Respondents failed to prove payment of the stated consideration (P111,180.00), and the deed’s notarization did not cure its intrinsic flaws. Thus, TCT No. T-356656, derived from a void deed, was likewise void.
The Supreme Court held that petitioners sufficiently proved the deed’s nullity due to absence of consideration and forgery, warranting reconveyance of the property.