Title
Aron vs. Court of Appeals
Case
G.R. No. 126926
Decision Date
Aug 16, 2001
Aron's claim over a Bacoor property was dismissed due to prescription and late filing; subsequent buyers were deemed innocent purchasers for value.
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Case Digest (G.R. No. 126926)

Facts:

Background of the Case

The case involves a dispute over a 35,718 square meter parcel of land in Bacoor, Cavite, originally owned by Paciencia Perrin. On April 3, 1963, Perrin entered into a Contract to Sell with Ramon P. Aron (petitioner) for the property, with a total consideration of P25,000.00, payable in installments over 15 years. The last installment was due on April 3, 1983. Upon full payment, Perrin was obligated to execute a Deed of Absolute Sale and deliver the title to Aron.

Breach of Contract

Despite Aron’s full payment of the purchase price by April 3, 1983, Perrin failed to execute the Deed of Absolute Sale or deliver the title. Aron later discovered that Perrin had authorized Jose M. Dragon to sell the same property to Doña Juana Development, Inc. in September 1972. Aron demanded compliance from Perrin, but she failed to act. He also wrote to Doña Juana, which acknowledged his claim but offered to repurchase the land.

Filing of the Complaint

On July 23, 1993, Aron filed a Complaint for Specific Performance, Annulment of Contract and Title, Reconveyance, and Damages (Civil Case No. 93-89) against Perrin, Doña Juana, and other subsequent buyers. He sought to compel Perrin to execute the Deed of Sale, annul the subsequent sales, and reconvey the land to him. He also claimed moral and exemplary damages, attorney’s fees, and litigation expenses.

Motions to Dismiss

Several defendants filed Motions to Dismiss on the grounds of lack of cause of action and prescription. The trial court granted the motions, ruling that the defendants were innocent purchasers for value, and the action for reconveyance could not prosper. The Court of Appeals affirmed this decision.


Issue:

  1. Whether the decision of the Court of Appeals has become final due to the late filing of petitioner’s motion for reconsideration.
  2. Whether petitioner’s cause of action has prescribed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court denied the petition, ruling that Aron’s action had prescribed and that the Court of Appeals’ decision had become final due to the late filing of the motion for reconsideration. The Court emphasized the importance of timely filing actions and the protection afforded to innocent purchasers for value.


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