Heirs of Domingo Hernandez, Sr. v. Hernandez (Surviving Spouse)

Summary

The Supreme Court denied the petition of heirs of Domingo Hernandez Sr. seeking reconveyance of property allegedly transferred through forged documents. While the Court found that the wife's signature on the Special Power of Attorney was indeed forged, it ruled that the sale of conjugal property by the husband without wife's consent was merely voidable, not void, under Civil Code Article 173. The wife had ten years from the transaction and during the marriage to seek annulment. Since the action was filed after the husband's death in 1983 and beyond the ten-year prescriptive period from the 1963 transaction, the claim had prescribed. Additionally, the Court applied the doctrine of laches, noting the heirs' unreasonable delay of 17 years during which respondents possessed and improved the property, plus another 12 years after discovering the title cancellation before filing suit. The lengthy inaction and respondents' continuous possession, tax payments, and improvements barred the reconveyance claim.