G.R. No. 187661 - Sanchez vs. Sanchez

A Deed of Absolute Sale was executed on November 25, 1981, conveying a parcel of land from respondent Andrew Sanchez to petitioner Modesto Sanchez.
The Deed explicitly indicated that the property covered by Transfer Certificate of Title (TCT) No. 143744 was sold to Modesto.
Andrew challenged the deed as a sham document, contending it was replete with falsehood and fraudulent misrepresentations.

Andrew admitted he had sent a pre-signed deed of sale to Modesto in response to an offer made by the latter to purchase his property.
He alleged that the transaction never materialized because Modesto did not have the financial wherewithal to complete the purchase at that time.
Furthermore, Andrew claimed that the pre-signed deed was sent undated and not notarized.
Multiple attempts by Andrew to retrieve the document from Modesto were unsuccessful.

Despite the failed transaction, Andrew allowed Modesto to occupy the property, where their ancestral home was built.
This liberality was later extended to Modesto’s live-in partner, Juanita H. Yap, as evidenced by the execution of a Bequest of Usufruct.
In 2000, Modesto, through Yap, allegedly renewed an offer to purchase the property, which Andrew refused.

Andrew later discovered that his certificate of title was missing and filed an Affidavit of Loss with the Registry of Deeds of Manila.
Subsequently, Andrew learned that Modesto had filed a Petition for Reconstitution of TCT No. 143744, based on the earlier deed which by then appeared notarized.
This spurred Andrew to file a complaint seeking the annulment of the deed of sale, cancellation of the new title issued in Modesto’s name, and reconveyance of the title.

In the lower court, Modesto raised affirmative and special defenses, citing lack of cause of action, prescription, and laches.
Motions were filed setting forth these defenses, with Andrew submitting an opposition to the defendant’s affirmative defenses, followed by Modesto’s reply.

The RTC dismissed Andrew’s complaint on December 28, 2006, ruling that the action was time-barred by prescription due to the lapse of time since the purported sale.
The RTC further held that Andrew’s failure to provide any valid reason for the delay in asserting his right amounted to laches.
The dispositive portion of the RTC’s order dismissed both Andrew’s complaint and Modesto’s counterclaims.

Andrew elevated his case to the Court of Appeals (CA), challenging whether the RTC erred in dismissing the complaint on the grounds of prescription and laches.
The CA critiqued the premature dismissal, emphasizing that the validity or voidability of the deed—and whether the contract truly was consummated—could only be ascertained via a full trial.
Consequently, the CA reversed the RTC decision and remanded the case for trial and judgment on the merits, declining to rule on costs.

Whether the RTC erred in dismissing Andrew’s complaint on the grounds of prescription and laches without affording a full-blown trial to address evidentiary disputes.

Whether the Deed of Absolute Sale is void, voidable, or valid—a determination that directly impacts the applicability of the prescription defense.

Whether the factual disputes, including whether the purchase price was ever paid and the implications of non-payment, necessitate a trial rather than a summary resolution based solely on pleadings.