Case Summary (A.C. No. 8210)
Facts
In 1979, Carmencita Naval-Sai obtained a parcel of land identified as Lot No. 54-B (LRC) Psd 39172, evidenced by Transfer Certificate of Title (TCT) No. T-19586. The land was subdivided under her name, with specific focus on Lots No. 54-B-8 and No. 54-B-9, covered by TCTs No. T-58334 and No. T-58335. Later, Naval-Sai sold Lot No. 54-B-76 under the condition that the deed of sale would only be executed upon full payment. However, subsequent payment defaults led to a complicated transfer of interest involving several parties, including the petitioner, Aniceto Uy.
Legal Proceedings and Claims
Naval-Sai initiated legal action to annul a deed of sale that purportedly transferred ownership of Lots No. 54-B-8 and No. 54-B-9 to Uy, claiming forgery regarding her signature on the deed. The case unfolded in Branch 17 of the Regional Trial Court (RTC) of Kidapawan City, where the RTC ruled in favor of Uy. Naval-Sai appealed, asserting that the deed was fraudulent and sought to cancel the titles recently issued in Uy’s name, which the RTC dismissed based on prescription and a defective certification against forum shopping.
Court of Appeals' Findings
The Court of Appeals, upon review, deemed that there was substantial compliance with the certification requirements concerning forum shopping. It reasoned that the verification in the original complaint was valid, negating Uy’s claims of procedural defects. Additionally, the Court of Appeals concluded that Naval-Sai's action to annul the deed was not a collateral attack on the titles and observed that it constituted a direct action for reconveyance, which has different prescription rules than typical contractual disputes.
Ruling on Petitioner's Claims
Uy contended that the Court of Appeals erred by recognizing substantial compliance with the forum shopping certification requirements and also argued that the case had prescribed due to delayed action by Naval-Sai. The ruling of the Supreme Court clarified that the verification must be by the party, yet the nature of Naval-Sai's action was ultimately for reconveyance based on a claim of a void contract, which does not prescribe.
Legal Analysis
The resolution pointed out the crucial distinction between actions based on void contracts, which are imprescriptible, and those that might be subject to a statute of limitations. The Supreme Court reiterated that a claim based on alleged forgery, if proven, qualifies as an action on a void contract, thus exempting it from the limitations applicable to other typ
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Facts and Procedural Posture
- Carmencita Naval-Sai acquired ownership in 1979 of Lot No. 54-B from her brother, later subdivided into various lots including Lots No. 54-B-8 and 54-B-9, subject of the case, registered under corresponding Transfer Certificates of Title (TCTs).
- Naval-Sai sold another lot, No. 54-B-76, on installment to Bobby Adil under conditional absolute sale, but Adil defaulted; he then sold the incomplete building on that lot to spouses Francisco and Louella Omandac.
- Naval-Sai borrowed money from Grace Ng, delivering TCT Nos. T-58334 and T-58335 (covering Lots No. 54-B-8 and 54-B-9) as security. Ng in turn secured a loan from petitioner Uy by delivering the same titles.
- Petitioner Uy filed a recovery of possession case against Francisco Omandac; RTC Branch 17 ruled in favor of Uy, leading to Omandacs’ ejection from the property and Uy’s possession.
- Naval-Sai contested the alleged deed of sale used as basis for title transfer to petitioner, filing an annulment of deed with damages before the same RTC branch, asserting her signature on the purported deed of sale was forged and that she never sold the lots.
- Naval-Sai amended the complaint to declare the TCTs issued under petitioner’s name to be null and void ab initio, adding relief for cancellation of said titles.
- Petitioner denied the titles were delivered as loan security and asserted the validity of a 1981 contract of sale, claiming ownership and possession over the lots.
- Petitioner also raised defenses including defective certification against forum shopping and prescription, denying jurisdiction acquisition due to failure of Naval-Sai to personally certify non-forum shopping.
- RTC dismissed the complaint on grounds of prescription and defective certification against forum shopping, ruling the action was a prohibited collateral attack on titles that had become indefeasible after one year from registration.
- The RTC also found Naval-Sai’s certification inadequate as it was signed by counsel, not the party herself, and she failed to explain non-compliance.
- The Court of Appeals set aside the RTC dismissal, ruling substantial compliance with certification requirements existed due to the original complaint’s proper certification and that the action is not a collateral attack nor prescribed, characterizing it as a direct annulment/reconveyance action.
- The Court of Appeals emphasized the issue of forgery was unresolved and remanded the case for further proceedings.
- Petitioner’s motion for reconsideration was denied, leading to the present petition raising issues on certification compliance and prescription/laches/estoppel.
Issues Presented
- Whether there was substantial compliance with the certification against forum shopping requirement.
- Whether the action filed by Naval-Sai has prescribed or should