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PERFECTO MACABABBAD v. FERNANDO G. MASIRAG

FACTS:

Respondents Fernando Masirag, Faustina Masirag, Corazon Masirag, Leonor Masirag, and Leoncio Masirag Goyagoy filed a complaint against petitioners Perfecto Macababbad, Jr., Chua Seng Lin, and Say Un Ay. The complaint included allegations of quieting of title, nullity of titles, reconveyance, damages, and attorney's fees against the petitioners. The respondents claimed that the petitioners falsified a document entitled "Extra-judicial Settlement with Simultaneous Sale of Portion of Registered Land (Lot 4144)", which resulted in the deprivation of their shares in Lot No. 4144. The said document conveyed the subject property to Macababbad, who then registered portions of Lot No. 4144 in his name and sold other portions to third parties. Chua also filed a petition for the cancellation of a Transfer Certificate of Title and the issuance of a new title in his name covering a portion of Lot No. 4144. Initially, the trial court denied the petitioners' motion to dismiss the amended complaint, but later reconsidered and dismissed the complaint. The respondents appealed the trial court's dismissal order to the Court of Appeals (CA).

The respondents' complaint alleged that fraud was committed against them as successors-in-interest of the original owners of a property. They asserted that they were deprived of their interests due to the deception. The Regional Trial Court (RTC) originally dismissed the complaint for failure to implead indispensable parties. However, the CA reversed the RTC's decision, stating that the complaint had a cause of action and that the respondents' cause of action had not prescribed. The petitioners then filed a petition for review on certiorari before the Supreme Court, which initially denied the petition but later reinstated it. In their motion for reconsideration, the petitioners raised various grounds including the CA's lack of jurisdiction, failure to implead indispensable parties, and erroneous interpretation of Civil Code provisions. The respondents argued that the appeal raised mixed questions of fact and law and that the action had not yet prescribed or lapsed due to laches.

ISSUES:

  1. Whether the issues raised in the respondents' appeal with the Court of Appeals involve questions of fact.

  2. Whether the respondents' appeal was properly filed through an ordinary appeal.

  3. Whether the action for annulment of the extrajudicial settlement of estate and sale, based on forged signatures, had already prescribed.

  4. Whether the issuance of certificates of title in the name of the petitioners converts the action to one of reconveyance, subject to the prescriptive period of ten years.

  5. Whether the action for the declaration of the inexistence of a contract has prescribe

  6. Whether laches can be invoked in this case

  7. Whether the dismissal based on non-joinder of indispensable parties is proper

  8. Whether or not the petitioner's right to due process was violated when he was convicted of murder based solely on circumstantial evidence.

  9. Whether or not the prosecution was able to prove the petitioner's guilt beyond reasonable doubt.

RULING:

  1. Yes, the issues raised in the respondents' appeal with the Court of Appeals involve questions of fact. The determination of whether prescription applies necessitates a consideration of factual matters such as the date when the period to bring the action commenced to run.

  2. Yes, the respondents' appeal was properly filed through an ordinary appeal. Since the appeal raised mixed questions of fact and law, the respondents were correct in invoking the appellate jurisdiction of the Court of Appeals through an ordinary appeal.

  3. The action for the nullity of the extrajudicial settlement of estate and sale does not prescribe due to its nature. The action is based on fraud and the claim of forgery, and therefore falls under Article 1410 of the Civil Code, which states that actions to declare a contract null and void do not prescribe.

  4. The issuance of certificates of title in favor of the petitioners does not convert the action to one of reconveyance subject to the prescriptive period of ten years. The issuance of the certificates of title does not vest ownership of the entire property upon the petitioners, and it does not validate the null and void purchase. Registration only serves as evidence of title, and the land registration laws do not give the holder any better title than what they actually have. Therefore, the sale to the petitioners has no legal effects whatsoever.

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

  6. Laches cannot be invoked in this case.

  7. Dismissal based on non-joinder of indispensable parties is not proper.

  8. No, the petitioner's right to due process was not violated. Circumstantial evidence is admissible in proving guilt as long as the following elements are present: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a moral certainty that the accused committed the crime.

  9. Yes, the prosecution was able to prove the petitioner's guilt beyond reasonable doubt. The circumstantial evidence presented by the prosecution, when taken collectively, established the petitioner's presence at the crime scene, his motive to commit the crime, and his opportunity to do so. These circumstances, coupled with his failure to establish an alibi, led to a moral certainty of his guilt.

PRINCIPLES:

  • A question of law arises when there is doubt as to what the law is on a certain state of facts, while a question of fact arises when doubt arises as to the truth or falsity of alleged facts. A question of law may be resolved by the court without reviewing or evaluating the evidence, while questions of fact necessitate a calibration of the evidence. (Crisostomo v. Garcia)

  • Prescription may be a question of law or fact depending on whether the doubt or controversy arises as to the truth or falsity of an allegation of fact, or as to what the law is on a given state of facts. The test to determine whether a question is one of law or fact is whether the appellate court can determine the issue raised without reviewing or evaluating the evidence. (Crisostomo v. Garcia)

  • A summary or outright dismissal of an action is improper where there are factual matters in dispute which require presentation and appreciation of evidence. (Ingjug-Tiro v. Casals)

  • The three modes of appeal from decisions of the Regional Trial Court are: (1) ordinary appeal or appeal by writ of error, which is taken to the Court of Appeals on questions of fact or mixed questions of fact and law; (2) petition for review, which is brought to the Court of Appeals on questions of fact, of law, or mixed questions of fact and law; and (3) petition for review to the Supreme Court, which is elevated to the Supreme Court only on questions of law. (Murillo v. Consul)

  • A ruling on prescription requires an analysis of the plaintiff's cause of action based on the allegations of the complaint and the documents attached as its integral parts. A motion to dismiss based on prescription hypothetically admits the relevant and material allegations of the complaint, but not the other facts of the case. (Unknown)

  • Actions to declare a contract null and void do not prescribe under Article 1410 of the Civil Code.

  • Registration of land does not vest title; it is merely evidence of such title.

  • The sale of property is null and void if the vendors are not the owners of the property being sold.

  • A contract made after the death of a party is null and void, as death terminates contractual capacity.

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

  • Laches is a doctrine in equity and cannot be used against the positive mandate of a statutory law.

  • Misjoinder or non-joinder of parties is not a ground for the dismissal of an action.

  • Indispensable parties are those who possess an interest in the controversy that a final decree would necessarily affect their rights so that the courts cannot proceed without their presence.

  • Failure of an appellate court to rule on an issue raised in an appeal does not render the appealed order or judgment final and executory with respect to the undiscussed issue.

  • Circumstantial evidence is admissible in proving guilt as long as the elements of the circumstantial evidence test are satisfied.

  • In establishing guilt beyond reasonable doubt in a murder case, it is not necessary to present direct evidence of the commission of the crime. Circumstantial evidence, when taken collectively, may be sufficient to prove the accused's guilt.