Facts:

• In "Pangadil v. Court of First Instance of Cotabato, Branch I," petitioners led by Salandang Pangadil sought to annul a document titled "Ratificacion De Una Venta."
• The document acknowledged the sale of land originally owned by their father, Pangadil Maslamama.
• The land was orally conveyed to private respondents in December 1941.
• In 1946, Salandang Pangadil petitioned the Court of First Instance of Cotabato to be appointed guardian of her minor siblings to formalize the verbal sale.
• The court granted the petition, and the document was executed and approved in 1947.
• The guardianship proceeding was closed in 1948.
• On January 7, 1969, the petitioners filed Civil Case No. 2187 to annul the document and the court order approving it, claiming the transaction was a mortgage, not a sale.
• Respondents filed a motion to dismiss, arguing the action had prescribed and was barred by a prior judgment.
• The respondent court dismissed the case, declaring the document legal and binding, and ruled the action to annul the sale was barred by the statute of limitations.
• Petitioners sought review on certiorari from the Supreme Court.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court ruled that the document "Ratificacion De Una Venta" is not inexistent and void ab initio.
2. The Supreme Court affirmed the respondent...(Unlock)

Ratio:

• The Supreme Court held that the imprescriptibility of an action to declare the inexistence of a contract applies only to contracts expressly enumerated in Article 1409 of the Civil Code.
• The facts did not support categorizing the document as inexistent and void ab initio.
• The court found no basis to claim the execution of the document was contrary to public policy.
• The conveyance of the land by the petitioners' father during his lifetime was acknowledged by the petitioners.
• Even if the execution of the deed was attended by fraud, it would make the contract voidable, not inexistent and void.
• An action to annul a voidable contract based on fraud ...continue reading