Zenaida M. Santos v. Calixto Santos

Summary

The Supreme Court affirmed the nullification of two deeds of sale involving a Manila property, ruling they were simulated transactions. Despite formal transfer documents, the original owners Jesus and Rosalia Santos continued to possess, administer, and benefit from the property, collecting rentals and paying taxes. The Court found that the deeds were executed merely to accommodate their son Salvador's business needs, not to transfer actual ownership. The presumption of delivery through public instruments was rebutted by clear evidence of continued control by the original vendors. The Court ruled that actions to declare void contracts imprescriptible and found no laches in the four-year delay. This case reinforces that formal documentation alone cannot establish valid property transfer without actual delivery and transfer of control, emphasizing the importance of substance over form in property transactions.