Felix Gochan v. Heirs of Raymundo Baba

Summary

This Supreme Court case involves a property dispute over Lot No. 3537, originally owned by spouses Raymundo and Dorotea Baba. After Raymundo's death, some heirs executed an extrajudicial settlement and sold the property to Gochan Realty without the knowledge or consent of five other alleged heirs. The excluded heirs filed a complaint for quieting of title and reconveyance 28 years later. The trial court dismissed the case on prescription and laches grounds, but the Court of Appeals reversed. The Supreme Court affirmed the reinstatement but clarified that the action seeks to declare the contracts void ab initio for lack of consent rather than enforce a constructive trust based on fraud. The Court held that actions to declare the inexistence of contracts due to absence of essential requisites do not prescribe under Article 1410 of the Civil Code, establishing the important principle that 'nemo dat quod non habet' - no one can give more than what he has. The case was remanded for trial on the merits.