FACTS:

The case involves a Complaint for Declaration of Nullity of Sale, Reconveyance, and Damages filed by respondents against petitioner. The disputed property is a 98,851-square meter parcel of land originally registered in the name of Felicisima Udiaan. The respondents claim to be the grandchildren and successors-in-interest of Udiaan, who inherited the land. However, an impostor pretending to be Udiaan sold the land to petitioner, causing the cancellation of Udiaan's title and the issuance of a new title in petitioner's name. The petitioner then occupied and used the land for his livestock business.

The respondents sought the nullification of the sale and the return of the land. The Regional Trial Court (RTC) dismissed the case for lack of merit, ruling that the respondents were not the real parties in interest. On appeal, the Court of Appeals (CA) upheld the dismissal but also declared the nullity of the sale and redistributed portions of the land to different parties. The petitioner filed a motion for reconsideration, but it was denied. Thus, the petitioner filed a petition before the Supreme Court. The main issue for resolution is whether the Court of Appeals (CA) correctly nullified the sale and redistributed portions of the land despite ruling that the respondents were not the real parties in interest.

ISSUES:

1. Whether or not the CA correctly declared the nullity of the Questioned Deed of Absolute Sale and distributed portions of the subject land to different parties, among others, despite ruling that respondents are not real parties in interest to the instant case.

RULING:

1. Yes, the CA correctly declared the nullity of the Questioned Deed of Absolute Sale and distributed portions of the subject land to different parties. The CA agreed with the RTC's finding that respondents are not real parties in interest to the instant case. However, it nullified the Questioned Deed of Absolute Sale because it was clearly executed by a person other than Udiaan, who died more than 20 years before such sale occurred. Considering that some of Udiaan's heirs had already sold a portion of the subject land to the Heirs of Gaccion, who in turn, sold a portion to petitioner, the CA apportioned the subject land accordingly.

PRINCIPLES:

• Real parties in interest. Only real parties in interest may institute an action. (citing Civil Code, Art. 1311)

• Nullity of a contract. A contract is null and void if it is entered into by a person who is already dead at the time the sale occurred.