- Petitioner
- Spouses Mariano Castillo
- Respondent
- Heirs of Vicente Madrigal And/Or Susana Realty
- Citation
- G.R. No. 62650
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Medialdea, J.
- Decided
- June 27, 1991
Summary
The Castillo spouses sought annulment of a deed of sale and reconveyance of their property, claiming they never consented to its transfer to Vicente Madrigal and subsequently to Susana Realty Inc. The Supreme Court recognized that actions for declaration of inexistence of contracts are imprescriptible when consent is completely absent, distinguishing this from voidable contracts tainted by fraud. However, the Court denied the petition because the property had been transferred to an innocent purchaser for value (Susana Realty Inc.), and petitioners failed to allege bad faith on the purchaser's part. The case establishes that while void contracts can be attacked at any time, protection of innocent purchasers for value remains paramount in property disputes. The decision balances the imprescriptible nature of actions against truly void contracts with the security of land titles and protection of good faith purchasers.