Maria Cabotaje v. Spouses Sotero Pudunan

Summary

This case involves a dispute over land ownership where heirs of deceased Bonifacia Lang-ew mortgaged one lot and sold another to respondent spouses. The respondents fraudulently altered the deed of sale after execution to include both properties without additional consideration or the heirs' consent. The Supreme Court reversed the Court of Appeals, holding that the altered deed was null and void ab initio due to lack of consent, not merely voidable. The Court emphasized that substantial alterations made without parties' knowledge and consent render a contract void. Since the action was for declaration of non-existence of a contract under Article 1410 of the Civil Code, it was imprescriptible. The case establishes important precedent on distinguishing void from voidable contracts and the imprescriptible nature of actions to declare contract non-existence.