- The Dela Cruz sisters later on filed a case before the RTC to render such

11. Spouses Narciso Rongavilla V. CA deed of sale void on the basis that they were fraudulently acquired which
G.R. 83974 the RTC affirmed despite the defense of the Rongavilla that the action has
8-17-1998 already prescribed after 4 years
By: Clyne - The CA also affirmed the decision of the RTC
Topic: Acquisitive prescription; Tacking; Extinctive Prescription - Hence, this petition to the Supreme Court
Petitioners: Spouses Narciso Rongavilla and Dolores Rongavilla
Respondents: CA & Mercedes Dela Cruz & Florencia Dela Cruz ISSUE
Ponente: J. Quisumbing Whether the Rongavilla spouses can raise the defense of prescription

HELD
RECIT-READY/SUMMARY: Rongavilla spouses and Dela Cruz sisters each owns 50%
No, the judgement of the CA is affirmed
of the property in question. The sisters acquired a loan from the spouses and that
they were made to sign a document evidencing their loan. After quite some time,
RATIO
the spouses later on evicted the sisters since the document that they signed was a
The Supreme Court held that the Dela Cruz sisters were really misled by the
deed of sale. The sisters filed a case before the RTC, which the RTC and CA affirmed
Rongavilla spouses into believing that the document they signed was a document
that the deed of sale is a void contract. The spouses elevated the case to the SC
acknowledging a loan. Hence, the consent doesn’t exist in the first place. The cause
averring the defense of prescription but the SC ruled otherwise since there was no
of the contract is also missing since the property mortgaged amounted to
valid contract in the first place thereby not being subjected to prescription.
P40,000.00 which is in stark contrast with the price written in the deed of sale
which amounted to P2,000.00. Lastly, on the issue of prescription, the Supreme
DOCTRINE: A void contract can’t be subjected to prescription
Court ratiocinated that the document in question is declared void thereby making
the statute of limitations inapplicable in this case since under the eyes of the law,
FACTS
there is no contract in the first place.
- The property in question in this case is co-owned between Mercedes and
Florencia Dela Cruz (1st party) who are sisters and the Rongavilla Spouses
(2nd party)
- Both parties owns 50% of the property in question
- The Dela Cruz sisters obtained a loan from the Rongavilla spouses
amounting to P2, 000.00 for the repairs for the rooftop of their house
- Later on, the Rongavilla spouses went to the Dela Cruz sisters (who is the
aunt of Mrs. Rongavilla) in order to fraudulently make them sign a
document alleged to evidence a P2, 000.00 loan which is written in
English (The Dela Cruz sisters doesn’t know how to speak English)
- After 4 years, the Rongavilla spouses went to the house of the Dela Cruz
sisters and asked them to vacate the land in question on the basis that
they are alleged to be the real owner of the land
- The Dela Cruz sisters went to the Register of Deeds and discovered that
the Certificate of Title was replaced with a new one which entails that
such land was issued in favor of the Rongavilla spouses and that it was
also mortgaged in favor of Cavite Development Bank
- Such transfer of title occured because the document that they previously
signed was a deed of sale and not a negotiable instrument which
represented their indebtedness to the Rongavilla spouses