Title
Brito, Sr. vs. Dianala
Case
G.R. No. 171717
Decision Date
Dec 15, 2010
A land dispute involving heirs of Esteban Dichimo, with respondents claiming rightful ownership through reconveyance after their intervention was dismissed; SC upheld CA, affirming jurisdiction and imprescriptibility due to respondents' possession.
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Case Digest (G.R. No. 171717)

Facts:

Ownership and Dispute Over the Land

  • The subject of the case is a parcel of land located at Barrio Sicaba, Cadiz City, Negros Occidental, which is part of Lot No. 1536-B, formerly known as Lot No. 591-B.
  • The land was originally owned by Esteban Dichimo and his wife, Eufemia Dianala, both deceased.
  • On September 27, 1976, Margarita Dichimo (petitioner's wife) and other heirs of Vicente and Eusebio Dichimo filed a Complaint for Recovery of Possession and Damages against Jose Maria Golez, docketed as Civil Case No. 12887.
  • The complainants claimed to be the heirs of Vicente and Eusebio Dichimo, who were the only heirs of Esteban and Eufemia.

Intervention by Respondents

  • On July 29, 1983, respondents (Severino D. Dianala et al.) filed an Answer-in-Intervention, asserting that Esteban was previously married to Francisca Dumalagan, with whom he had five children. Respondents claimed to be the heirs of these children and argued that they had been in open, actual, and uninterrupted possession of a portion of the land for over 30 years.
  • On November 26, 1986, the trial court dismissed respondents' Answer-in-Intervention for failure to secure legal representation.

Compromise Agreement and Subsequent Cases

  • The parties in Civil Case No. 12887 entered into a Compromise Agreement, dividing Lot No. 1536-B between Golez and the heirs of Vicente Dichimo. The heirs of Eusebio Dichimo had sold their share to Golez’s mother.
  • On September 9, 1998, the RTC of Bacolod City approved the Compromise Agreement, and TCT No. T-12561 was issued in the names of Margarita, Bienvenido, and Francisco Dichimo.
  • On January 18, 1999, petitioner and his co-heirs filed a Complaint for Recovery of Possession and Damages against respondents (Civil Case No. 548-C).
  • On August 18, 1999, respondents filed a Complaint for Reconveyance and Damages against petitioner and his co-heirs (Civil Case No. 588-C).

RTC and CA Proceedings

  • On June 29, 2000, the RTC dismissed both cases: Civil Case No. 548-C for forum shopping and Civil Case No. 588-C for lack of jurisdiction.
  • Respondents appealed to the CA, which reversed the RTC’s dismissal of Civil Case No. 588-C and remanded the case for trial on the merits.
  • Petitioner filed a Motion for Reconsideration, which the CA denied.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction and Strangers to a Case: Respondents ceased to be parties in Civil Case No. 12887 after their Answer-in-Intervention was dismissed. As strangers to the case, they were not bound by the judgment rendered therein.
  2. Prescription of Reconveyance Actions: An action for reconveyance based on an implied trust prescribes in ten years from the issuance of the title. Respondents filed their complaint within this period, and their possession of the property made the action imprescriptible.
  3. Nature of Reconveyance Actions: Respondents’ action was not an attempt to annul the decision in Civil Case No. 12887 but a separate action to recover their rightful share in the property.
  4. Due Process and Equity: Respondents were entitled to due process and the opportunity to prove their claims, as depriving them of their property without a hearing would violate constitutional guarantees.


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