Heirs of Romana Ingjug-Tiro: Bedesa v. Spouses Leon V. Casals

Summary

This case involves a property inheritance dispute over a 5,354-square meter land originally owned by Mamerto Ingjug who died during WWII. Some of his heirs sold the property in 1965 to respondents, claiming to be the only surviving heirs and excluding other rightful heirs. The excluded heirs discovered the sale in 1990 and filed suit in 1992 for partition and nullification of the sale documents. The trial court and Court of Appeals dismissed the case on grounds of prescription and laches. However, the Supreme Court reversed, ruling that actions to declare the inexistence of contracts that are null and void ab initio are imprescriptible under Article 1410 of the Civil Code. The Court found that the sale was potentially void for including shares of non-consenting heirs and for possible forgery (Francisco Ingjug allegedly signed a 1967 document despite dying in 1963). The case was remanded for trial on the merits, establishing the important principle that prescription and laches cannot bar claims involving contracts that are void from the beginning.