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    People of The Philippines vs. Mizpah R. Reyes

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    Anonymous 91f03cw
    Spouses owned land that was registered under their names. After their death, their daughter Mizpah Reyes had the land transferred to her name alone through a deed of sale with the spouses' signatures. The complainants, who are also children of the deceased spouses, later discovered that the signatures were forged. They filed criminal cases against Reyes for falsification and making false statements more than 20 years after the deed was registered. The courts ruled that the criminal action had prescribed as the prescriptive period started from registration of the deed, not from discovery of the falsification.

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    People of The Philippines vs. Mizpah R. Reyes

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    Anonymous 91f03cw
    429 views1 page
    Spouses owned land that was registered under their names. After their death, their daughter Mizpah Reyes had the land transferred to her name alone through a deed of sale with the spouses' signatures. The complainants, who are also children of the deceased spouses, later discovered that the signatures were forged. They filed criminal cases against Reyes for falsification and making false statements more than 20 years after the deed was registered. The courts ruled that the criminal action had prescribed as the prescriptive period started from registration of the deed, not from discovery of the falsification.

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    Spouses owned land that was registered under their names. After their death, their daughter Mizpah Reyes had the land transferred to her name alone through a deed of sale with the spouses' signatures. The complainants, who are also children of the deceased spouses, later discovered that the signatures were forged. They filed criminal cases against Reyes for falsification and making false statements more than 20 years after the deed was registered. The courts ruled that the criminal action had prescribed as the prescriptive period started from registration of the deed, not from discovery of the falsification.

    Copyright:

    © All Rights Reserved
    429 views1 page

    People of The Philippines vs. Mizpah R. Reyes

    Uploaded by

    Anonymous 91f03cw
    Spouses owned land that was registered under their names. After their death, their daughter Mizpah Reyes had the land transferred to her name alone through a deed of sale with the spouses' signatures. The complainants, who are also children of the deceased spouses, later discovered that the signatures were forged. They filed criminal cases against Reyes for falsification and making false statements more than 20 years after the deed was registered. The courts ruled that the criminal action had prescribed as the prescriptive period started from registration of the deed, not from discovery of the falsification.

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    of 1

    PEOPLE OF THE PHILIPPINES

    vs.

    MIZPAH R. REYES

    FACTS:

    Spouses Julio Rizare and Patricia Pampo owned a parcel of land in Lipa City registered in their
    names under a TCT. Both are now deceased and were survived by the following children: the accused
    Mizpah R. Reyes and the complainants. In 1983, the complainants discovered from the Register of Deeds
    (RD) that the subject property had already been transferred in the name of Mizpah Reyes, single, under a
    TCT. They alleged that the conveyance was through a deed of sale executed and signed by their parents.
    Upon examination in the RD of the document, they found that the signature of their parents were falsified
    and that accused also made an untruthful statement that she was single although she was married. The N.B.I.
    found that the signature of Julio Rizare was genuine but that of Patricia Pampo was forged. The
    complainants filed 2 informations against Reyes for falsification and for allegedly making an untruthful
    statement of fact in the deed of sale. The trial court granted the motion of Reyes to quash the informations
    stating that the lapse of more than twenty (20) years before the two informations were filed, the crimes for
    which the accused, Mizpah Reyes, are charged have already prescribed. The People now filed an appeal in
    the CA who affirmed the decision of the RTC. The CA ruled that the prescriptive period started when the
    deed of sale was registered in the RD and not when the falsification was discovered. Hence, this petition
    for review on certiorari.

    ISSUE: W/N the petitioner’s action against Reyes has already prescribed.

    HELD:

    Yes, the action has already prescribed. The rule is well-established that registration in a public
    registry is a notice to the whole world. The record is constructive notice of its contents as well as all
    interests, legal and equitable, included therein. Under the rule of notice, it is presumed that the purchaser
    has examined every instrument of record affecting the title. Such presumption is irrebutable. This
    presumption cannot be overcome by proof of innocence or good faith. The notarized deed of sale was
    registered on May 26, 1961. The criminal informations for falsification of a public document having been
    filed only on October 18, 1984, or more than ten (10) years from May 26, 1961, the crime for which the
    accused was charged has prescribed. The Court of Appeals, therefore, committed no reversible error in
    affirming the trial court's order quashing the two informations on the ground of prescription

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