Title
Macababbad, Jr. vs. Masirag
Case
G.R. No. 161237
Decision Date
Jan 14, 2009
Heirs alleged fraud in property transfer via forged extrajudicial settlement; SC upheld CA, ruling action imprescriptible, remanding for fraud determination.

Case Digest (G.R. No. 161237)
Expanded Legal Reasoning Model

Facts:

  • Parties and Procedural History
    • Petitioners
      • Perfecto Macababbad, Jr. (deceased, substituted by his heirs: Sophia Macababbad, Glenn M. Macababbad, Perfecto Vener M. Macababbad III, and Mary Grace Macababbad)
      • Spouses Chua Seng Lin and Say Un Ay
    • Respondents and Intervenors
      • Respondents: Fernando G. Masirag, Faustina G. Masirag, Corazon G. Masirag, Leonor G. Masirag, and Leoncio M. Goyagoy
      • Intervenors/respondents: Francisca Masirag Baccay, Pura Masirag Ferrer-Melad, and Santiago Masirag
    • Procedural Timeline
      • April 28, 1999: Respondents filed a complaint at the Regional Trial Court (RTC) challenging petitioners’ dealings over Lot No. 4144
      • May 10, 1999: Complaint amended to include additional allegations
      • July–September 1999: Petitioners raised motions to dismiss while respondents furthered the proceedings, including an intervention motion on December 14, 1999
      • May 29, 2000: RTC rendered an Order dismissing the complaint based on prescription and non-joinder of indispensable parties
      • Subsequent Appeal: Respondents appealed the dismissal to the Court of Appeals (CA); the CA reversed the RTC decision and remanded the case for further proceedings
      • Petition for Review on Certiorari: Petitioners subsequently filed a petition for review on certiorari challenging the CA ruling
  • Background of the Disputed Property and Alleged Transactions
    • Original Ownership and Property Details
      • The property (Lot No. 4144) originally owned by Pedro Masirag and Pantaleona Tulauan, covering an area of 6,423 square meters, as evidenced by Original Certificate of Title No. 1946
      • The deceased parents left eight children; respondents are among the descendants, with their relationships outlined in the amended complaint
    • Alleged Fraudulent Transaction
      • Petitioners are accused of executing an extrajudicial settlement and simultaneous sale, dated December 3, 1967, purporting to transfer portions of Lot No. 4144
      • The document allegedly bears forged signatures of the respondents, making it appear as though they had consented to the sale
      • The extrajudicial settlement resulted in the cancellation of the OCT and the issuance of a new Transfer Certificate of Title (TCT No. 13408) in the names of new owners
      • Despite irregularities, aspects of the transaction were subsequently employed by petitioners, including actions to acquire an owner's duplicate copy of the TCT and to subdivide portions of the lot
  • Contentions and Arguments Raised
    • Respondents' Position
      • The complaint sought declaratory relief: nullity of the extrajudicial settlement, reconveyance of the property, and damages/attorney’s fees
      • They argued that the fraudulent document deprived them of their rightful inherited shares and that the action to nullify such a document is imprescriptible (by Article 1410 of the Civil Code)
      • Additional assertions included that the action was not barred by prescription (especially considering the discovery of the alleged fraud in March 1999), and that non-joinder of certain co-heirs did not warrant dismissal
    • Petitioners' Position
      • Asserted that errors within the respondents’ appeal were purely questions of law not subject to the CA’s mixed jurisdiction
      • Raised the contention that the RTC dismissal based on prescription and failure to implead indispensable parties should be upheld
      • Emphasized that the issuance of TCTs and other documentary evidence should convert the action into one for reconveyance subject to a ten-year prescriptive period
    • CA’s Handling and Determinations
      • Ignored the petitioners’ motion to dismiss based on jurisdictional issues
      • Addressed two main issues: sufficiency of the cause of action stating fraud and whether the cause was extinguished by prescription
      • Held that the respondents’ cause of action—seeking the nullity of the extrajudicial settlement—remained valid and imprescriptible, even if the document led to the issuance of TCTs
      • Concluded that questions of mixed fact and law, such as prescription, should be resolved on presentation of evidence, rather than through a summary dismissal
  • Final Resolution at the Supreme Court Level
    • The petition for review on certiorari filed by the petitioners was examined in light of the CA’s decision and arguments concerning prescription, laches, and implementation of indispensable parties
    • The Supreme Court, finding the petition devoid of merit, denied the petition, thus upholding the CA’s ruling

Issues:

  • Jurisdiction and Nature of the Questions Raised
    • Whether the appeal raised pure questions of law or mixed questions of fact and law, thereby fitting within the CA’s appellate jurisdiction
    • Whether the petitioners’ arguments for dismissal on jurisdictional grounds were tenable
  • Validity of the Extrajudicial Settlement and Alleged Fraud
    • Whether the extrajudicial settlement and simultaneous sale, purportedly executed in 1967, is null and void ab initio due to fraud, misrepresentation, and forgery
    • Whether the forged signatures attributed to respondents invalidate the document and the resulting title transfers
  • Prescription and the Effect of Issued TCTs
    • Whether the action is barred by prescription considering the alleged delay in filing the complaint (ten-year rule for reconveyance versus four-year rule from discovery of fraud)
    • Whether the issuance of Transfer Certificates of Title affects the fundamental nature of the remedy being sought, especially in relation to the alleged nullity arising from fraud
  • Non-joinder of Indispensable Parties
    • Whether the failure to implead all co-heirs and innocent purchasers as indispensable parties constitutes a valid ground for dismissing the complaint
    • The proper application of Rule 3, Section 11 of the Rules of Court in allowing amendments or the joining of parties at later stages

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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