G.R. No. 190901 - Cotoner-Zacarias vs. Spouses Revilla

Case Summary (G.R. No. 190901)

Underlying Transaction and Alleged Forgery

In 1983, the Revilla spouses borrowed funds from Amada, agreeing verbally to vest possession of their land in her and apply its fruits to loan repayment. Unbeknownst to them, Amada presented a falsified “Kasulatan ng Bilihan ng Lupa” dated March 19, 1979, forging their signatures to effect a transfer of Tax Declaration No. 7971 to her name.

Subsequent Transfers of Unregistered Land

Amada sold the property to Spouses Adolfo and Elvira Casorla on August 25, 1984; they in turn sold to Spouses Rodolfo and Yolanda Sun on December 16, 1991. Each sale was supported by unregistered deeds and successive tax declarations, none challenged until 1994–1995.

Trial Court Findings and Decision

On November 17, 1995 the Revilla spouses filed for annulment of all transfers and reconveyance of title. In August 2006, RTC Branch 18 declared the forged document void ab initio, annulled all subsequent transfers, reinstated title and possession to the Revilla spouses, and awarded damages against Amada and the Sun spouses.

Court of Appeals Ruling

In August 2009 CA-G.R. CV No. 88600 dismissed Amada’s appeal and partially granted the Sun spouses’ appeal by ordering interest adjustments on the damage awards. CA upheld the RTC’s forgery finding and the nullity of the transfers, modifying interest rates on principal, moral and exemplary damages, and attorney’s fees.

Issues Presented

Does laches or prescription bar the Revilla spouses’ cause of action?
Did trial court acquire jurisdiction despite payment of docket fees based on P50,000 claimed damages rather than the P12,000,000 property value mentioned at pretrial?
Was reinstatement and reconveyance of the property proper in view of antichresis, conjugal-property and good-faith purchaser defenses?

Supreme Court on Prescription and Laches

SC held the suit was filed within nine months of discovery of the forgery (served Feb. 15, 1995; complaint filed Nov. 17, 1995). Under Civil Code Art. 1410, actions to declare a contract nonexistent are imprescriptible. Laches, an equity doctrine, cannot override statutory imprescriptibility or bar timely assertion of rights.

Supreme Court on Docket Fees and Jurisdiction

Jurisdiction depends on the amount prayed in the original complaint. Revilla spouses prayed for P50,000 actual damages and paid fees accordingly. Mention of P12,000,000 at pretrial—absent formal amendment—was immaterial (Manchester Dev. Corp. v. CA; Supreme Court Circular No. 7). Trial court thus validly acquired jurisdiction.

Supreme Court on Reinstatement and Reconveyance

The Rev