GR 83974; (August, 1998) (Digest)
G.R. No. 83974 August 17, 1998
SPOUSES NARCISO RONGAVILLA and DOLORES RONGAVILLA, petitioners, vs. COURT OF APPEALS and MERCEDES DELA CRUZ and FLORENCIA DELA CRUZ, respondents.
FACTS
Private respondents Mercedes and Florencia dela Cruz, spinsters of advanced age and aunts of petitioner Dolores Rongavilla, owned a parcel of land in Las Piñas. In May 1976, they borrowed P2,000 from petitioners to repair their roof. In June 1976, petitioner Dolores Rongavilla and her sister Juanita Jimenez visited the respondents and presented a document typewritten in English for their signature. When asked what it was, Dolores represented in Tagalog that it was merely a document to evidence the P2,000 debt. Relying on this representation, the respondents signed the document. In September 1980, petitioners demanded that respondents vacate the land, claiming ownership. Upon verification, respondents discovered the document they signed was a Deed of Absolute Sale, their Original Certificate of Title had been cancelled, and a new Transfer Certificate of Title had been issued in the petitioners’ name, which was then mortgaged for P40,000. Respondents filed a complaint to declare the deed void and inexistent due to fraud, misrepresentation, lack of consent, and want of consideration. The trial court and the Court of Appeals ruled in favor of the respondents, declaring the deed void and ordering reconveyance. Petitioners appealed to the Supreme Court.
ISSUE
Did the Court of Appeals commit reversible error in upholding the trial court’s judgment that the disputed Deed of Absolute Sale is void and inexistent?
RULING
No, the Court of Appeals did not commit reversible error. The Supreme Court affirmed the decisions of the lower courts. The deed was declared void and inexistent due to the absence of consent (vitiated by fraud and misrepresentation) and the want of a true cause or consideration. The P2,000 mentioned was a loan, not a purchase price, as evidenced by the gross inadequacy of the amount compared to the property’s value (the property was later mortgaged for P40,000). The respondents, being elderly, unschooled in English, and in a position of moral dependence, were misled into signing a document they believed merely acknowledged a debt. An action to declare a void contract inexistent does not prescribe. The Court also found the order for reconveyance proper. The petition was denied.