Title
Armamento vs. Guerrero
Case
G.R. No. L-34228
Decision Date
Feb 21, 1980
Plaintiff claims land possession since 1955, alleges defendant obtained title via fraud. Supreme Court remands for full hearing, citing implied trust and timely action.
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Case Digest (G.R. No. L-34228)

Facts:

  1. Parties and Subject Matter:

    • Plaintiff: Sotero Armamento
    • Defendant: Cipriano Guerrero
    • Disputed Property: Lot No. 974, PLS-247-D, Klinan 6, Polomolok, South Cotabato, approximately 11 hectares.
    • Title: Original Certificate of Title No. V-16135 issued to defendant based on Free Patent No. V-19129 granted on July 20, 1961.
  2. Plaintiff’s Claims:

    • Plaintiff claims to be the actual possessor and homestead applicant of the land since 1955.
    • He filed Homestead Application No. 37-31 on July 7, 1959, which was approved on January 6, 1964.
    • Plaintiff alleges that defendant obtained the title through fraud and misrepresentation by falsely claiming continuous possession since July 4, 1945.
  3. Defendant’s Defense:

    • Defendant denies plaintiff’s claims, asserting that he has been in possession of the land and authorized someone to administer it while he was away for missionary work.
    • He filed his Free Patent Application on August 1, 1958, prior to plaintiff’s application.
    • Title was issued to defendant on July 20, 1961.
  4. Procedural History:

    • Plaintiff filed the case on January 27, 1967, seeking reconveyance, declaration of an implied trust, and damages.
    • The trial court dismissed the case on February 14, 1968, citing lack of cause of action, prescription, and improper party.
    • Plaintiff appealed to the Court of Appeals, which certified the case to the Supreme Court due to purely legal issues.

Issue:

  1. Whether the trial court erred in dismissing the case without a full hearing on the merits.
  2. Whether the plaintiff has a cause of action for reconveyance or declaration of an implied trust.
  3. Whether the action has prescribed.
  4. Whether the plaintiff has the legal personality to file the action for reconveyance.

Ruling:

The Supreme Court ruled in favor of the plaintiff and remanded the case to the trial court for a full hearing on the merits. The Court held that:

  1. The trial court erred in dismissing the case without a full hearing, as the plaintiff’s allegations of fraud and misrepresentation required further examination.
  2. The plaintiff’s action for reconveyance is not barred by prescription, as it is based on an implied trust, which has a prescriptive period of ten years.
  3. The plaintiff, while not the legal owner, may invoke equity and the doctrine of implied trust under Article 1456 of the Civil Code.
  4. The trial court should determine the validity of the issuance of the Free Patent and the title.

Ratio:

  1. Equity Jurisdiction:

    • Courts of equity have the authority to retain jurisdiction and decide all issues to achieve full justice between the parties.
    • The doctrine of implied trust under Article 1456 of the Civil Code may apply if the defendant acquired the title through fraud or misrepresentation.
  2. Prescription:

    • An action for reconveyance based on an implied trust prescribes in ten years.
    • The plaintiff’s action, filed within five years of the title issuance, is timely.
  3. Proper Party:

    • While the plaintiff is not the legal owner, he may still seek reconveyance or invoke an implied trust if he can prove fraud or misrepresentation by the defendant.
  4. Remedy for Fraud:

    • Even if the title is indefeasible after one year, an action for reconveyance is available if the property has not passed to an innocent purchaser for value.


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