Amada Cotoner-Zacarias v. Spouses Alfredo Revilla

Summary

The Supreme Court affirmed the nullification of property transfers involving a 15,000 square-meter unregistered land in Silang, Cavite, based on a forged deed of sale. The Revilla spouses had verbally agreed to let Amada Cotoner-Zacarias possess their property as security for a loan, with earnings from cultivation to pay the debt and taxes. However, Amada fraudulently created a fictitious deed of sale dated 1979 and transferred the tax declaration to her name, then sold the property to successive buyers. The Court held that the forged signature rendered the initial sale void ab initio, making all subsequent transfers invalid. The decision emphasized that actions to declare contracts inexistent do not prescribe under Article 1410 of the Civil Code, and that buyers of unregistered land cannot claim good faith protection available only for registered Torrens titles. The property was ordered reconveyed to the original owners with damages awarded against the perpetrator of the fraud.