Philippine General Council of the Assemblies of God v. Heirs of Segundo Morales

Summary

The Supreme Court denied a petition challenging the validity of a 1964 land sale involving one hectare of homestead property. The heirs of Segundo Morales filed an action to annulment the sale, claiming no valid deed existed or was fraudulently obtained. The Philippine General Council of the Assemblies of God moved to dismiss on prescription grounds, arguing over 33 years had elapsed since the title was issued in 1965. The Court ruled that actions for declaration of inexistence of contracts are imprescriptible under Article 1410 of the Civil Code. Since evidentiary matters were involved regarding the contract's existence, the issue could not be resolved on a motion to dismiss but required a full trial. The decision emphasizes that prescription defenses must be apparent from the complaint's face to warrant dismissal, and the permanent, incurable nature of contract inexistence makes such actions immune from prescription.