Francisca Salomon v. Intermediate Appellate Court

Summary

Petitioners Francisca Salomon and Abraham Gatdula challenged the validity of a property transfer based on an alleged forged deed of extrajudicial partition and sale. The lot originally belonged to Macario Salomon and was inherited by his daughters. In 1973, petitioners discovered their property had been transferred to respondent Araceli Calimbas through a 1953 deed which PC experts found to contain forged signatures. The trial court nullified the deed and restored the original title, but the Court of Appeals reversed this decision. The Supreme Court ultimately sided with petitioners, ruling that the deed was indeed forged and void ab initio, making the action imprescriptible under Article 1410 of the Civil Code. The Court emphasized that expert testimony on forgery, combined with other circumstantial evidence including the physical condition of the document and the absence of petitioner during the alleged signing, established the nullity of the transaction. This case reinforces the principle that forged documents convey no title and that actions to declare void contracts do not prescribe.