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