The Supreme Court, in this case, reiterated that an action to declare the nullity of a contract, particularly an extrajudicial settlement of estate with a forged signature, is imprescriptible. This means that there is no time limit to file a case to declare such a document void. This ruling protects the rights of individuals whose signatures have been forged on legal documents, ensuring that they can always seek redress in court regardless of how much time has passed since the forgery occurred.

Unraveling Inheritance Rights: Can Forged Documents Nullify a Family’s Legacy?

This case originated from a complaint filed by the respondents, Fernando Masirag, et al., against Perfecto Macababbad, Jr. and the spouses Chua Seng Lin and Say Un Ay, alleging falsification of an “Extra-judicial Settlement with Simultaneous Sale of Portion of Registered Land.” The respondents claimed their signatures were forged, depriving them of their shares in Lot No. 4144, which originally belonged to their deceased parents, Pedro Masirag and Pantaleona Tulauan. The Regional Trial Court (RTC) initially dismissed the case based on prescription and failure to implead indispensable parties. However, the Court of Appeals (CA) reversed the RTC’s decision, leading to this petition for review before the Supreme Court. The central legal question revolves around whether the action to nullify the extrajudicial settlement, given the alleged forgery, has prescribed and whether indispensable parties were properly impleaded.

The petitioners argued that the CA lacked jurisdiction to rule on the appeal, contending that the errors raised involved pure questions of law. They further asserted that the RTC’s dismissal due to the non-impleading of indispensable parties had become final and that the respondents’ cause of action had prescribed. However, the Supreme Court found that the appeal involved mixed questions of fact and law, particularly regarding the determination of when the prescriptive period began to run. This determination necessitated a review of the evidence, placing the case within the CA’s appellate jurisdiction.

Building on this principle, the Court emphasized the distinction between questions of law and questions of fact. A question of law arises when the issue involves determining the applicable law based on a certain set of facts. Conversely, a question of fact emerges when there is doubt or disagreement about the truth or falsity of the alleged facts. The Court noted that prescription can be a question of fact when the date of commencement of the action is disputed, requiring the examination and evaluation of evidence.

Focusing on the issue of prescription, the Court examined the respondents’ claim that their signatures were forged on the extrajudicial settlement of estate and sale. The Court stated, that if the respondents’ claim is true then it could invalidate the agreement. If a deed is found to be absolutely fictitious, it produces no legal effect, rendering any subsequent transfer based on that deed also void.

Article 1410 of the Civil Code explicitly states: “The action or defense for the declaration of the inexistence of a contract does not prescribe.”

Regarding the non-joinder of indispensable parties, the Court referenced Rule 3, Section 11 of the Rules of Court, which provides that neither misjoinder nor non-joinder of parties is a ground for dismissal of an action. The proper remedy is to implead the indispensable party at any stage of the action. The court may order the inclusion of indispensable parties, and only upon unjustified failure or refusal to obey the order to include or amend is the action dismissed. An indispensable party is defined as one whose interest in the controversy is such that a final decree would necessarily affect their rights, making it impossible for the court to proceed without their presence.

In conclusion, the Supreme Court found no reversible error in the CA’s decision. The Court affirmed that the respondents’ action to declare the nullity of the extrajudicial settlement of estate and sale was imprescriptible and that the non-joinder of indispensable parties was not a ground for immediate dismissal of the case. The case was remanded for further proceedings to determine the merits of the respondents’ claims.

FAQs

What was the main issue in this case?	The main issue was whether the action to nullify an extrajudicial settlement of estate with a forged signature had prescribed.
What does “imprescriptible” mean?	Imprescriptible means that there is no time limit to file a legal action. In this case, an action to declare a void contract never prescribes.
Can a case be dismissed for not including all interested parties?	No, the Rules of Court state that non-joinder of parties is not a ground for dismissal. The court should order the inclusion of the missing party.
What happens if a signature on a legal document is forged?	If a signature is proven to be forged, the document can be declared void from the beginning (void ab initio), having no legal effect.
What is an extrajudicial settlement of estate?	An extrajudicial settlement is a way to divide the estate of a deceased person among the heirs without going to court, typically through a notarized agreement.
What is the effect of a Transfer Certificate of Title (TCT) if the underlying sale is void?	A TCT does not validate a void sale. Registration merely provides evidence of title, and a void sale remains invalid even with a TCT.
What is an indispensable party in a legal case?	An indispensable party is someone whose presence is necessary for the court to make a complete and final decision in a case because their rights would be directly affected.
What is the difference between a question of law and a question of fact?	A question of law concerns the correct application of the law, while a question of fact concerns the truth or falsity of alleged facts, requiring evidence and evaluation.
What is laches, and does it apply in this case?	Laches is the failure to assert one’s rights promptly, which can lead to a loss of those rights. It does not apply in this case as it requires evidence, and the case never reached that stage.

This ruling highlights the importance of ensuring the validity of legal documents, especially those concerning property rights and inheritance. The Supreme Court’s decision underscores the principle that forged documents have no legal effect and that individuals deprived of their rights due to fraudulent acts can always seek legal recourse, regardless of the passage of time.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Perfecto Macababbad, Jr. v. Fernando G. Masirag, G.R. No. 161237, January 14, 2009