SPOUSES JAIME AND TEODORA VILLANUEVA, PETITIONERS, VS. THE HONORABLE COURT OF APPEALS AND CATALINA I. SANCHEZ, RESPONDENTS.

Villanueva versus Court of Appeals

The Case

This is a petition brought by spouses Jaime and Teodora Villanueva against the Court of Appeals and Catalina Sanchez, arising from a complaint for the annulment of a deed of sale, cancellation of a Torrens title, and reconveyance of a parcel of land in Rosario, Cavite. Catalina Sanchez claimed to be the widow of the late Roberto Sanchez, the registered owner, and alleged that the deed of sale in favor of the petitioners was a forgery. The case matters because it gathers in one decision several rules a reviewee must hold: the best evidence of a marriage is the marriage contract itself, a Torrens certificate proves ownership but not civil status, a forged deed of sale is absolutely void or inexistent, and the action to declare its inexistence does not prescribe.

Procedural History

Catalina Sanchez filed her complaint before the Regional Trial Court of Cavite. On motion of the petitioners, the trial court ordered the National Bureau of Investigation to examine the deed of sale for forgery. After trial, Judge Alejandro Silapan rendered judgment in favor of the petitioners, holding that the deed of sale was not spurious, that the action to annul it had prescribed, that Catalina Sanchez was not the widow of Roberto Sanchez, and that she had no capacity to institute the complaint. Catalina Sanchez appealed, and the Court of Appeals reversed the trial court, finding that the vendor's signature on the questioned document had indeed been forged. The petitioners then came to the Supreme Court, urging that the decision of the trial court be reinstated.

Facts

Roberto Sanchez owned a parcel of land of 275 square meters in Rosario, Cavite. He was issued a Torrens certificate over the land on August 25, 1965, and that certificate described his civil status as single. Catalina Sanchez claimed to be his widow and submitted a marriage contract dated September 21, 1964. The land was later registered in the name of the petitioners on the strength of an alleged deed of sale executed in their favor by Roberto Sanchez on February 7, 1968.

Catalina Sanchez invoked the report of a handwriting expert from the Philippine Constabulary Criminal Investigation Service, who found that the signature on the document was written by another person. She prayed that the deed of sale be annulled, that the registration in the name of the petitioners be canceled, and that the lot be reconveyed to her. The petitioners, in their answer, questioned her personality, contending that Roberto Sanchez was never married but had a common-law wife by whom he had two children. On the merits, they claimed that Roberto Sanchez had deeded the lot to them in 1968 for 500 pesos in partial settlement of a judgment they had obtained against him, after he failed to pay a 1,300 peso loan they had secured for him and which they had been forced to settle themselves.

At trial, both the Philippine Constabulary examiner and the National Bureau of Investigation examiner testified that the signature on the deed of sale was not written by Roberto Sanchez. The trial judge rejected their testimony, saying that Roberto Sanchez was under serious emotional stress and intensely angry when he reluctantly signed the document, and that the signatures compared did not include those written by him in 1968. The Court of Appeals reversed, and the case reached the Supreme Court.

Issues

• Whether or not Catalina Sanchez proved her status as the widow of Roberto Sanchez.
• Whether or not she had the capacity to file the complaint for the recovery of her late husband's property.
• Whether or not the signature of Roberto Sanchez on the deed of sale was forged.
• Whether or not the action to annul the deed of sale had already prescribed.
• Whether or not Catalina Sanchez and her late husband were estopped from questioning the deed of sale.

Applicable Provisions

Article 1409 of the Civil Code provides:

The following contracts are inexistent and void from the beginning: (1) Those whose cause, object or purpose is contrary to law, morals, good customs, public order or public policy; (2) Those which are absolutely simulated or fictitious; (3) Those whose cause or object did not exist at the time of the transaction; (4) Those whose object is outside the commerce of men; (5) Those which contemplate an impossible service; (6) Those where the intention of the parties relative to the principal object of the contract cannot be ascertained; (7) Those expressly prohibited or declared void by law.

The Court uses this provision to classify the forged deed of sale as absolutely simulated or fictitious, and therefore totally void or inexistent.

Article 1410 of the Civil Code provides:

The action or defense for the declaration of the inexistence of a contract does not prescribe.

This is the rule the Court applies to the question of prescription, in place of the four year period for annulment.

Article 1391 of the Civil Code provides:

The action for annulment shall be brought within four years. This period shall begin: In cases of intimidation, violence or undue influence, from the time the defect of the consent ceases. In case of mistake or fraud, from the time of the discovery of the same. And when the action refers to contracts entered into by minors or other incapacitated persons, from the time the guardianship ceases.

The Court holds this provision inapplicable because the deed of sale suffers from none of the vices it lists.

Article 1431 of the Civil Code provides:

Through estoppel an admission or representation is rendered conclusive upon the person making it, and cannot be denied or disproved as against the person relying thereon.

The Court finds no admission or representation by Catalina Sanchez or her late husband on which the petitioners relied, so estoppel does not arise.

Ruling

On the first issue, the Court holds that Catalina Sanchez proved her status as the widow of Roberto Sanchez with her submission of the marriage contract. That evidence rendered unnecessary the presumption that a man and a woman deporting themselves as husband and wife have entered into a lawful contract of marriage. It was error for the trial court to reject the marriage contract in favor of the Torrens certificate describing Roberto Sanchez as single, for the best documentary evidence of a marriage is the marriage contract itself, and a Torrens certificate is the best evidence of ownership of registered land, not of the civil status of the owner.

On the second issue, the Court holds that as the surviving spouse, Catalina Sanchez could validly file the complaint for the recovery of her late husband's property, without prejudice to the successional rights of his other heirs.

On the third issue, the Court holds that the signature of Roberto Sanchez on the deed of sale was forged. It notes that the National Bureau of Investigation examination was requested by the petitioners themselves, yet it was the private respondent who presented the National Bureau of Investigation expert as her own witness, because the findings of the two government examiners coincided. Their conclusion was supported by knowledgeable testimony on the characteristics and differences of the signatures examined, their competence was never assailed, and the petitioners presented no handwriting expert of their own. The Court itself examined the signatures in the records, including those dating back to before 1968, and accepted the findings of the experts. The tension said to have gripped Roberto Sanchez was a mere conjecture of the trial judge, unsupported by proof. The thirteen year delay in registering the deed was likewise not convincing.

On the fourth issue, the Court holds that the applicable rule is not Article 1391 but Article 1410. The deed of sale suffers from none of the vices of annulment. The supposed vendor's signature having been proved to be a forgery, the instrument is totally void or inexistent as absolutely simulated or fictitious under Article 1409, and under Article 1410 the action for the declaration of the inexistence of a contract does not prescribe.

On the fifth issue, the Court holds that estoppel does not apply. The inference that Roberto Sanchez and the private respondent knew of the instrument from its execution was not proved, and neither of them made any admission or representation to the petitioners regarding the subject land that the petitioners relied upon.

Doctrine

First, the best documentary evidence of a marriage is the marriage contract itself. A Torrens certificate of title is the best evidence of ownership of registered land, not of the civil status of the owner.

Second, the surviving spouse has the capacity to sue for the recovery of the property of the deceased spouse, without prejudice to the successional rights of the other heirs.

Third, a deed of sale whose vendor's signature is forged is totally void or inexistent, as absolutely simulated or fictitious under Article 1409 of the Civil Code.

Fourth, the action for the declaration of the inexistence of a contract does not prescribe under Article 1410, so a forged deed may be challenged at any time. The four year period of Article 1391 governs only annulment for intimidation, violence, undue influence, mistake, fraud, or lack of capacity.

Fifth, estoppel under Article 1431 requires an admission or representation by the party sought to be estopped upon which the other party relied.

Disposition

The petition was denied and the decision of the Court of Appeals was affirmed, with costs against the petitioners.

Remember This

Memorize this line: a forged deed of sale is absolutely void or inexistent under Article 1409, and the action to declare its inexistence does not prescribe under Article 1410. Examiners use this case to test the distinction between annulment and declaration of inexistence, and to test whether you know that a Torrens title proves ownership but never civil status.