Title
Amerol vs. Bagumbaran
Case
G.R. No. L-33261
Decision Date
Sep 30, 1987
Two claimants vie for ownership of disputed land; one obtains title via fraud, leading to a Supreme Court ruling for reconveyance after ten years, invalidating the fraudulent title and mortgage.
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Case Digest (G.R. No. L-33261)

Facts:

  1. Identity of the Land in Litigation: The disputed land is Lot No. 524, Pls-126, commonly known and technically described in the case. Both parties claim ownership of this land.
  2. Free Patent Applications: Two free patent applications were filed for the land:
    • Liwalug Datomanong (erroneously surnamed Amerol): Filed on September 4, 1953.
    • Molok Bagumbaran: Filed on December 27, 1954.
  3. Issuance of Title: Molok Bagumbaran’s application was granted, resulting in the issuance of Free Patent No. V-19050 on August 16, 1955, and Original Certificate of Title No. P-466 in his name.
  4. Possession and Cultivation: Liwalug Datomanong had been in continuous possession and cultivation of the land since 1952, introducing significant improvements such as coconut and coffee plantations, a mosque, and a farmhouse.
  5. Fraud Allegations: Liwalug Datomanong alleged that Molok Bagumbaran obtained the title through fraud and misrepresentation, as Bagumbaran falsely claimed to be in possession of the land when he was not.
  6. Protest and Counterclaim: Liwalug Datomanong filed a formal protest with the Bureau of Lands on April 24, 1964, and later included a counterclaim in his answer to Bagumbaran’s complaint, seeking annulment of the title or reconveyance of the land.
  7. Trial Court Decision: The trial court ruled in favor of Bagumbaran, declaring him the registered owner and dismissing Liwalug Datomanong’s counterclaim on the ground of prescription.

Issue:

  1. Prescriptive Period for Reconveyance: What is the prescriptive period for an action for reconveyance of real property wrongfully registered under the Torrens system? Is it four years or ten years?
  2. Fraud and Misrepresentation: Was Molok Bagumbaran guilty of fraud or misrepresentation in securing the free patent and title?
  3. Validity of Mortgage: Is the mortgage on the property, contracted by Bagumbaran with the Development Bank of the Philippines, valid and binding against Liwalug Datomanong?

Ruling:

  1. Prescriptive Period: The Supreme Court ruled that the prescriptive period for an action for reconveyance based on an implied or constructive trust is ten years, starting from the date of the issuance of the certificate of title.
  2. Fraud and Misrepresentation: The Court found that Molok Bagumbaran committed fraud and misrepresentation in securing the title, as he falsely claimed possession of the land when it was actually Liwalug Datomanong who was in possession.
  3. Reconveyance Ordered: The Court ordered the reconveyance of Original Certificate of Title No. P-466 to Liwalug Datomanong, free of any encumbrances.
  4. Invalidity of Mortgage: The mortgage on the property was deemed invalid against Liwalug Datomanong, as it was contracted by Bagumbaran in bad faith.

Ratio:

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