Spouses Patricio v. Heirs of Julian Sambaan

Summary

This Supreme Court case involved a family dispute over a 3,643 square meter property in Cagayan de Oro City originally owned by Julian Sambaan. The eldest daughter Myrna Bernales and her husband claimed ownership through a Deed of Absolute Sale dated December 7, 1970, but the other heirs challenged this document as forged. The NBI examination confirmed that the signatures of both Julian and his wife Guillerma were forged. All three court levels ruled in favor of the heirs, finding substantial evidence of forgery including expert testimony, visual examination of signatures, and circumstantial evidence showing Julian was unaware of any sale. The Supreme Court affirmed that forged deeds are void ab initio under the Civil Code and convey no title, even under the Torrens system. The Court also ruled that actions to declare the inexistence of void contracts do not prescribe, rejecting petitioners' prescription defense.