Perfecto Macababbad, Jr. v. Fernando G. Masirag

Summary

This case involves a property inheritance dispute where respondent heirs discovered in 1999 that their signatures were allegedly forged on a 1967 extrajudicial settlement document that purported to sell their shares in inherited land to petitioner Macababbad. The RTC dismissed their complaint for nullification and reconveyance on grounds of prescription and failure to implead indispensable parties. The Court of Appeals reversed, finding the action imprescriptible under Civil Code Article 1410. The Supreme Court affirmed the CA, ruling that actions to declare void contracts are imprescriptible, that the appeal properly raised mixed questions of fact and law within CA jurisdiction, that laches requires evidentiary proof, and that non-joinder of parties is not grounds for dismissal. The case was remanded for trial on the merits to determine whether the settlement document was indeed fraudulent.