The Supreme Court has clarified that an action for reconveyance of property based on a forged deed of sale does not prescribe, meaning there is no time limit to file such a case. This ruling protects rightful landowners from losing their property due to fraudulent transactions, ensuring that forgeries cannot be used to permanently deprive owners of their land. It reinforces the principle that void contracts, such as those resulting from forgery, have no legal effect and can be challenged at any time.

Unmasking Forgery: Can a Stolen Signature Steal Your Land?

In the case of Aniceto Uy v. Court of Appeals and Carmencita Naval-Sai, the central issue revolves around a complaint filed by Carmencita Naval-Sai seeking to annul a deed of sale, claiming her signature was forged. This purported deed transferred ownership of two land lots to Aniceto Uy. Naval-Sai argued she never consented to the sale, alleging the titles were only used as security for a loan. The Regional Trial Court (RTC) initially dismissed the case, citing prescription and a defective certification against forum shopping. However, the Court of Appeals (CA) reversed this decision, stating that the action was, in essence, one for reconveyance based on a void contract, which does not prescribe. This set the stage for the Supreme Court to rule on whether Naval-Sai’s action had prescribed and whether the certification against forum shopping was sufficient.

The Supreme Court first addressed the procedural issue of the certification against forum shopping. A **certification against forum shopping** is a sworn statement by a party assuring the court that they have not filed any other case involving the same issues. It is a personal responsibility of the party, not their counsel, unless the counsel is specifically authorized via a Special Power of Attorney (SPA). In this case, the original complaint had a proper certification, but the amended complaint’s certification was signed only by Naval-Sai’s counsel. While the Court acknowledged this defect, it ultimately ruled that there was **substantial compliance** because the original complaint contained a valid certification and the merits of the case warranted a relaxation of the rules. The Court emphasized that procedural rules are meant to facilitate justice, not to hinder it, citing Far Eastern Shipping Company v. Court of Appeals, stating that such rules “should be used to achieve such end and not to derail it.”

Building on this principle, the Supreme Court delved into the crucial issue of whether Naval-Sai’s action had prescribed. The petitioner, Uy, argued that the action should have been filed within one year from the registration of the titles, or, at most, within ten years based on the prescription period for reconveyance actions based on implied trust. However, the Court aligned with the Court of Appeals’ finding that Naval-Sai’s action was essentially one for **reconveyance based on a void contract**. An action for reconveyance aims to transfer property wrongfully registered in another person’s name back to the rightful owner.

The nature of the underlying contract determines whether an action for reconveyance prescribes. If the contract is merely voidable (e.g., consent obtained through fraud or mistake), the action generally prescribes within ten years, as outlined in Article 1456 of the Civil Code, which states, “If property is acquired through mistake or fraud, the person obtaining it is, by force of law, considered a trustee of an implied trust for the benefit of the person from whom the property comes.” However, if the contract is **void ab initio** (from the beginning) due to a complete absence of consent, such as in cases of forgery, the action is imprescriptible. In such cases, the law deems that no valid transfer ever occurred, and the rightful owner retains the right to reclaim their property indefinitely.

The Supreme Court distinguished between actions based on fraud (which prescribe) and those based on void contracts (which do not). It highlighted several cases, including Daclag v. Macahilig, where the Court held that an action for reconveyance based on a void deed of sale is imprescriptible. The Court also cited Castillo v. Heirs of Vicente Madrigal, where the plaintiffs alleged they never signed any document, emphasizing that “an action for the declaration of the inexistence of a contract does not prescribe.”

In Naval-Sai’s case, she alleged that the deed of sale was a complete forgery, meaning she never consented to the sale. If proven true, this would render the contract void ab initio. Therefore, the Supreme Court concluded that the action for reconveyance would not be subject to prescription. The Court emphasized that the RTC erred in dismissing the case without a full trial to determine the veracity of the forgery claim. The Court stated that “a summary or outright dismissal of an action is not proper where there are factual matters in dispute, which require presentation and appreciation of evidence.”

The Supreme Court also addressed the issue of laches, which is the unreasonable delay in asserting a right that prejudices the adverse party. The Court stated that laches is evidentiary in nature and cannot be established by mere allegations. Furthermore, the Court emphasized that laches is a doctrine in equity and cannot override statutory law. As such, the positive mandate of Article 1410 of the Civil Code, which confers imprescriptibility to actions for the declaration of the inexistence of a contract, prevails over arguments based on equity.

In conclusion, the Supreme Court denied the petition, remanding the case to the RTC for further proceedings. The RTC was ordered to conduct a full trial to determine whether the deed of sale was indeed forged. If found to be a forgery, the action for reconveyance would be imprescriptible, ensuring Naval-Sai’s right to reclaim her property.

FAQs

What was the key issue in this case?	The central issue was whether the action for reconveyance of property, based on an allegedly forged deed of sale, had prescribed. The Supreme Court clarified that if the deed is proven to be a forgery, the action does not prescribe.
What is a certification against forum shopping?	It is a sworn statement by a party assuring the court that they have not filed any other case involving the same issues, ensuring the efficient administration of justice. It must be executed by the party themselves, not their counsel, unless there’s a Special Power of Attorney.
What does “void ab initio” mean?	“Void ab initio” means void from the beginning. A contract that is void ab initio has no legal effect and cannot be validated.
What is an action for reconveyance?	An action for reconveyance is a legal remedy to transfer property wrongfully registered in another person’s name back to the rightful owner. The goal is to correct errors or fraud in property registration.
When does an action for reconveyance prescribe?	Generally, an action for reconveyance based on fraud prescribes in ten years. However, if the action is based on a void contract (e.g., forgery), it is imprescriptible.
What is the significance of Article 1410 of the Civil Code?	Article 1410 states that an action to declare the inexistence of a void contract does not prescribe. This is crucial in cases involving forgery, as it allows rightful owners to reclaim their property regardless of the time elapsed.
What is laches?	Laches is the unreasonable delay in asserting a right that prejudices the adverse party. However, it cannot override statutory law like Article 1410 of the Civil Code.
What was the Court’s ruling on the certification against forum shopping in this case?	The Court ruled there was substantial compliance despite the amended complaint’s certification being signed by counsel. The original complaint had a valid certification, and the merits of the case justified relaxing the rules.

This case underscores the importance of protecting property rights against fraudulent claims. The Supreme Court’s decision reinforces the principle that forgery cannot be a basis for validly transferring property. It ensures that rightful owners have the means to reclaim their land, even after a significant period, provided they can prove the deed of sale was indeed forged.

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: Aniceto Uy, G.R. No. 173186, September 16, 2015