G.R. No. L-25494 - Sanchez vs. Rigos

Teodora Rosario owned a 211.80-square meter land in Poblacion, San Carlos City, Pangasinan, covered by Transfer Certificate of Title (TCT) No. 12951.
She died intestate on January 19, 1970, leaving behind her spouse, Isidro Bautista, and five children: Teofilo, Alegria, Angelica, Pacita, and Gil Bautista.

On April 21, 1981, Isidro and four children (Pacita, Gil, Alegria, and Angelica) executed a Deed of Extra-Judicial Partition of the property; Isidro waived his share in favor of the four children.
Teofilo was excluded from this partition.
Alegria and Angelica, who received 1/12 of the property under the partition, sold their shares on May 14, 1981, to Pacita and her common-law husband Pedro Tandoc.
Pacita and Pedro secured tax declarations and TCT No. 18777 covering 209.85 sqm including the purchased shares.
On April 13, 1993, Pacita conveyed 1/12 of the property to Cesar Tamondong, Pedro’s nephew.

On January 24, 1994, petitioner Teofilo, through his attorney-in-fact Francisco MuAoz, filed a complaint against Alegria, Angelica, Pedro, Priscilla Bautista (widow of Gil), Priscilla’s children, and Cesar Tamondong for annulment of documents, partition, recovery of ownership and possession, and damages.
He alleged defrauding by co-heirs and challenged the validity of the deed of sale by Pacita, stating she was seriously ill and incapable of executing it.

Alegria, Angelica, and other defendants claimed Pacita caused the execution of the partition and they signed trusting her without scrutinizing the document. They only learned of the partition terms after the complaint was filed.
By cross-claim, they alleged that Pacita borrowed their shares as security for a business loan, signing a document she prepared, which turned out to be the deed of sale in Pacita’s favor.
Pedro and Cesar claimed to be buyers in good faith, and argued that prescription barred the complaint, which was a rehash of a previously dismissed case for document falsification.

Branch 57 of the Regional Trial Court (RTC) of San Carlos City rendered judgment on June 24, 1999, declaring null and void the Deed of Extra-Judicial Partition, the deed of sale dated May 14, 1981, TCT No. 18777, relevant tax declarations, and the April 13, 1993 sale to Tamondong.
Ordered partition of the land among all compulsory heirs of Isidro and Teodora.
Pedro and Cesar were ordered to vacate the premises.

On February 21, 2003, the Court of Appeals (CA) reversed the RTC decision and dismissed Teofilo’s complaint, applying the doctrine of prescription.
The CA held that the partition was invalid but Teofilo should have filed the action within the four-year prescriptive period from discovery of fraud, presumed constructive notice upon registration on December 21, 1981.
Even assuming an action for reconveyance based on implied trust, it prescribed after ten years from registration.
Thus, the complaint, filed in 1994, was beyond both prescriptive periods and barred.

Whether the Deed of Extra-Judicial Partition which excluded Teofilo was valid and binding.
Whether the causes of action for annulment of the partition deed and recovery of property had prescribed under applicable laws.
Whether subsequent transfers of the property to Pacita, Pedro, and Cesar Tamondong were valid and binding.