G.R. No. 197380 - Zuniga-Santos vs. Santos-Gran

On January 9, 2006, petitioner Eliza Zuaiga-Santos, through her attorney-in-fact Nympha Z. Sales, filed a Complaint for annulment of sale and revocation of title against respondents Maria Divina Gracia Santos-Gran and the Register of Deeds of Marikina City before the Regional Trial Court (RTC) of San Mateo, Rizal, docketed as Civil Case No. 2018-06.
The Complaint was later amended on March 10, 2006 (Amended Complaint).

Petitioner alleged ownership of three parcels of land in Montalban, Rizal, covered by Transfer Certificate of Title (TCT) Nos. N-5500, 224174, and N-4234 prior to their transfer to Gran.
She claimed to have a second husband, Lamberto C. Santos, with whom she had no children.
Petitioner alleged that she was forced to care for Gran, purported to be Lamberto’s daughter, whose birth certificate was allegedly forged to make her appear as petitioner’s daughter.
The subject properties were allegedly transferred to Gran through void and voidable documents, including a Deed of Sale executed by Lamberto.
Despite efforts, petitioner could not locate the Deed of Sale at the time of filing but discovered the transfer in November 2005.
Petitioner prayed for annulment of the sale, revocation of title, surrender of the properties, payment of damages, and costs of suit.

Prescription – as the action involves a written contract, it must be filed within ten (10) years from accrual, i.e., registration of documents with the Registry of Deeds.
Failure to state a cause of action – the void and voidable documents were neither identified nor described, precluding a valid judgment.

The Deed of Sale, an essential and indispensable document, was not attached to the Amended Complaint.
Certificates of title are not subject to collateral attack.
The action had prescribed under Article 1144 of the Civil Code being a written-contract case.

The Court of Appeals (CA) affirmed the dismissal but based it on insufficiency of factual basis, finding:

The Amended Complaint sufficiently alleged petitioner’s right prior to transfer, transfer through void and voidable documents, and Gran’s refusal to surrender.
The action was not prescribed since actions to nullify void deeds of conveyance are imprescriptible.
However, since the Deed of Sale was not attached, the court could not assess the forgery claim and therefore could not order reconveyance.

Petitioner moved for reconsideration, attaching for the first time a copy of the Deed of Sale allegedly recently recovered.
The CA denied the motion, ruling that admitting the document at this late stage would violate Gran’s right to due process.

Petitioner sought review on certiorari before the Supreme Court, assailing the CA Decision dated January 10, 2011 and Resolution dated June 22, 2011.

Whether the dismissal of petitioner’s Amended Complaint by the Court of Appeals and the Regional Trial Court should be sustained.
Whether the Amended Complaint failed to state a cause of action or lacked sufficient factual basis for an annulment of sale and revocation of title.
Whether the action filed by petitioner had prescribed.