GR L 54449; (July, 1984) (Digest)
G.R. No. L-54449 July 20, 1984
Eugenio Cabral and Sabina Silvestre, petitioners, vs. Court of Appeals, Silvino San Diego and Eugenia Alcantara, respondents.
FACTS
The controversy involves a 1/6 proindiviso portion of a registered lot. The spouses Silvino San Diego and Eugenia Alcantara claim that a 1948 deed of sale conveying this portion to the spouses Eugenio Cabral and Sabina Silvestre was a forgery. In 1974, the San Diegos filed a criminal case for falsification against Eugenio Cabral. The Court of First Instance dismissed the criminal charge on the ground of prescription, a dismissal later upheld by the Supreme Court.
Subsequently, the San Diegos filed a civil action in 1974 to nullify the title derived from the allegedly forged sale. The trial court dismissed this civil case, ruling that the dismissal in the criminal case for prescription constituted res judicata, thereby barring the civil suit. The San Diegos then filed a petition for certiorari with the Court of Appeals.
ISSUE
Whether the dismissal of the criminal case for falsification on the ground of prescription constitutes res judicata, barring a separate civil action to declare the underlying sale void and nullify the resulting title.
RULING
The Supreme Court ruled that the doctrine of res judicata does not apply. The dismissal of the criminal case for falsification based on the prescription of the crime is not a bar to the institution of a separate civil action seeking the declaration of the nullity of a contract and title. The two actions are fundamentally different in cause and purpose. The criminal action seeks penal liability for the act of falsification, which can prescribe. In contrast, the civil action attacks the very existence and validity of the contract itself, alleging it is void ab initio due to being forged or fictitious.
The Court clarified that an action for the declaration of the inexistence of a void contract, such as a forged deed of sale, is imprescriptible under Article 1410 of the Civil Code. The prescriptibility of the criminal offense is irrelevant to the imprescriptible character of an action to declare a null and void contract. Therefore, the trial court erred in dismissing the civil complaint on the ground of res judicata. The Court of Appeals correctly reversed the dismissal order and remanded the case for trial on the merits to determine the truth of the forgery allegation, without prejudging the outcome. The resolution of the Court of Appeals was affirmed.