Heirs of Spouses Luis Yanas v. Heirs of Spouses Antonio Acaylar

Summary

The Supreme Court reversed lower courts in this property dispute involving the validity of a 1950 deed of sale. Luis Yanas, an illiterate Subano who had occupied 13-hectare Lot No. 5408 since before 1926, allegedly sold the land to Antonio L. Acaylar for P200. After Yanas died in 1962, his heirs challenged the sale as fraudulent. The Supreme Court found the sale fictitious based on multiple badges of fraud: the deed was in English for an illiterate vendor, grossly inadequate consideration (P15.40 per hectare), wife's non-participation with incorrect name, delayed approvals and registration, contradictory witness testimonies, and discrepancies in notarial records. The Court declared the action for inexistence of contract does not prescribe under Article 1410 of the Civil Code, restoring ownership to Yanas' heirs and demonstrating protection of indigenous peoples' property rights against fraudulent transactions.