G.R. No. L-39378 - Ayson-Simon vs. Adamos

On December 13, 1943, Nicolas Adamos and Vicenta Feria (defendants-appellants) purchased two lots (approx. 56,395 sqm) forming part of the Piedad Estate in Quezon City from Juan Porciuncula, and obtained Transfer Certificate of Title No. 69475.
The successors-in-interest of Porciuncula later filed Civil Case No. 174 in the Court of First Instance of Quezon City seeking annulment of the sale and cancellation of TCT No. 69475.

On December 18, 1963, the CFI rendered judgment annulling the sale, canceling TCT No. 69475, and authorizing issuance of a new title in favor of Porciuncula’s successors.
The Appellate Court affirmed the decision and it became final and executory upon entry of judgment by the Court of Appeals on May 3, 1967.

On May 29, 1946, during the pendency of Civil Case No. 174, defendants sold the same two lots to Generosa Ayson-Simon (plaintiff-appellee) for ₱3,800.00 each, plus an additional ₱800.00 to facilitate issuance of new titles.
Plaintiff filed suit for specific performance on September 4, 1963, before the CFI of Quezon City. On January 20, 1964, the CFI ordered defendants to have the subdivision plan approved and to deliver titles and possession to plaintiff, deferring the hearing on damages. Execution proved impossible due to the prior annulment in Civil Case No. 174.

On August 16, 1968, plaintiff filed a new action for rescission of the sale with damages in the CFI of Manila.
On June 7, 1969, the CFI Manila rendered judgment ordering defendants, jointly and severally, to:

Whether plaintiff’s prior election of specific performance precludes her from seeking rescission.
Whether the action to rescind the sale has prescribed beyond the four-year period from the date of sale.