Case Digest (G.R. No. 52064)
Facts:
The case involves Juliana Caragay-Layno, assisted by her husband Benito Layno, as the petitioner, against the Honorable Court of Appeals and Salvador Estrada, the administrator of the estate of the deceased Mariano de Vera, as the respondents. The events leading to this case began with a dispute over a parcel of land located in Calasiao, Pangasinan, specifically a 3,732 square-meter area of a larger property totaling 8,752 square meters, covered by Original Certificate of Title No. 63. This title was issued on September 11, 1947, in the name of Mariano de Vera, who passed away in 1951 without any heirs. His estate was initially administered by his widow and later by his nephew, Salvador Estrada.
Juliana Caragay and Mariano de Vera were first cousins who lived together during their childhood under the care of a common aunt. The widow of de Vera filed an inventory of the deceased's properties, which included a parcel of land declared to be 5,147 square meters under Tax De...
Case Digest (G.R. No. 52064)
Facts:
Background of the Disputed Property
- The case involves a 3,732 square-meter portion of a larger parcel of land (Lot No. 1, Psu-24206) located in Calasiao, Pangasinan. The entire parcel, totaling 8,752 square meters, is covered by Original Certificate of Title (OCT) No. 63, issued on September 11, 1947, in the name of Mariano M. De Vera, who died in 1951 without issue.
- The estate of Mariano De Vera was administered first by his widow and later by his nephew, Salvador Estrada.
Petitioner’s Claim
- Petitioner Juliana Caragay-Layno, assisted by her husband Benito Layno, claimed ownership of the disputed portion. She alleged that the land originally belonged to her father, Juan Caragay, who had openly, continuously, and uninterruptedly possessed it in the concept of an owner since 1921.
- Upon her father’s death in 1914, Juliana adjudicated the property to herself as his sole heir in 1958 and declared it in her name under Tax Declaration No. 22522 in 1959. Realty taxes were consistently paid from 1938 to 1972.
Fraud Allegations
- Juliana claimed that the disputed portion was fraudulently included in OCT No. 63. She testified that Mariano De Vera, her first cousin, borrowed her tax declaration during his lifetime, purportedly to use it as collateral for a loan and sugar quota application. She alleged that she was made to sign documents without understanding their contents due to her illiteracy.
- She only discovered the fraudulent inclusion in 1966 when Salvador Estrada informed her that the disputed portion was registered under De Vera’s name.
Respondent’s Claim
- Salvador Estrada, as administrator of De Vera’s estate, demanded that Juliana vacate the disputed portion, asserting that it was part of the estate covered by OCT No. 63.
- Estrada filed a suit for recovery of possession (Civil Case No. D-2007), which Juliana resisted, counterclaiming for reconveyance of the property.
Lower Court Decisions
- The Trial Court ruled in favor of Estrada, ordering Juliana to vacate the disputed portion. The Court of Appeals affirmed the decision, holding that Juliana’s claim for reconveyance based on implied or constructive trust had prescribed after 10 years.
Issue:
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Ruling:
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Ratio:
Fraudulent or Mistaken Inclusion in Title
- The inclusion of the disputed portion in OCT No. 63 was erroneous, as it was not part of Mariano De Vera’s estate. The widow’s Inventory of Property, which listed only 5,147 square meters, effectively admitted that the disputed portion did not belong to the estate.
Prescription and Reconveyance
- An action for reconveyance based on implied or constructive trust prescribes in 10 years. However, when the claimant is in actual possession of the property, the action to quiet title is imprescriptible. Juliana’s undisturbed possession for over 45 years gave her a continuing right to seek reconveyance.
Laches
- The respondent’s failure to assert any rights over the disputed portion for 20 years from the registration of the title until the filing of the suit in 1967 constituted laches, barring their claim.
Indefeasibility of Torrens Title
- While a Torrens title is generally indefeasible, it does not protect holders who obtained the title through fraud or mistake. The inclusion of the disputed portion in OCT No. 63 was void, as the land registration court had no jurisdiction to decree the lot to persons who never asserted any right of ownership over it.
Equity and Continuing Right to Seek Relief
- Juliana’s undisturbed possession gave her a continuing right to seek the aid of a court of equity to determine the nature of the adverse claim and its effect on her title. Her right to seek reconveyance accrued only in 1966 when she was made aware of the adverse claim.