G.R. No. 76148 - Caro vs. Court of Appeals

The subject matter involves a 260 square meter parcel of land claimed by the petitioners (the heirs of Epifanio Caro) as being included in the larger parcel originally purchased by Epifanio Caro from Simeon Gallego.
The private respondents (Serafin V. Ronzales, Jose Ronzales, Jr., and Gemme Ronzales) contend that the disputed land is originally Pascuala Lacson’s property, later evidenced by an issued certificate of title.

On May 14, 1946, Simeon Gallego purchased a 5,031-square-meter parcel from several sellers in the poblacion of Jordan, Sub-Province of Guimaras, later declared under Tax Declaration No. 6437.
In 1948, Gallego sold this property to Epifanio Caro.
On May 15, 1962, Epifanio Caro acquired another parcel of 1,011 square meters (Tax Declaration No. 4135) from Trinidad Castem, Rolando Iranaya, and Eriberto Iranaya, heirs of Custodia Jalandoni.
Later in 1962, he purchased an additional 1,750-square-meter parcel from the heirs of Rafael Gaylan (Tax Declaration No. 3638).
In 1963, a survey consolidated these parcels into Lot No. 54. A subsequent survey in 1968 by the Sirilan Surveying Company resulted in the delineation of the properties into Lot No. 54 (for Epifanio Caro’s claim) and Lot No. 55 (claimed by the private respondents).
Epifanio Caro later consolidated the three surveyed lots into one, leading to the issuance of Tax Declaration No. 7688. However, during the cadastral proceedings, Epifanio Caro filed an answer only for Lot No. 54.

The private respondents maintained that the questioned land was originally owned by Pascuala Lacson and was declared in her name under Tax Declaration No. 4234.
Long before World War II, respondents and their predecessors were already occupying the land, as attested by the presence of a house constructed of semi-strong materials.
During a 1964 survey, the contested properties were again designated as Lot No. 54 (for Caro) and Lot No. 55 (for the respondents), and respective answers were filed—only for Lot No. 55 by Purificacion Ronzales representing the respondents.
Consequently, on September 17, 1970, Original Certificate of Title No. 0-6836 was issued in the names of the private respondents in equal shares.

In June 1973 and later 1974, separate ejectment and illegal detainer cases were initiated by Epifanio Caro related to other adjacent lots.
On June 4, 1975, Epifanio Caro filed a complaint (Civil Case No. 10235) for cancellation of the title, reconveyance, recovery of possession, and damages on the ground of fraud.
During the pendency of the case, Epifanio Caro died and was substituted by his heirs (the petitioners).
On November 22, 1982, the trial court dismissed the complaint, a decision subsequently affirmed by the Court of Appeals and the motion for reconsideration denied.
The petition for review on certiorari was thus brought before the Supreme Court for resolution of the controversy over the disputed land.

Whether or not the action for reconveyance filed in Civil Case No. 10235 prescribed under applicable law.

The petitioners argued that since the private respondents were mere trustees (not owners), prescription should not bar the action for reconveyance.
The trial and appellate courts applied a four-year prescriptive period relying on earlier case law and established that the complaint was filed too late.

Whether or not fraud attended the issuance of Original Certificate of Title No. 0-6836.

Determination of whether any fraudulent acts were employed in obtaining the Torrens title in favor of the private respondents.
Examination of the conduct of Epifanio Caro and the private respondents, particularly in relation to the boundaries and rental agreements noted during the transactions.

Whether or not Epifanio Caro (and subsequently his heirs) are estopped from questioning the ownership of the questioned land.

Consideration of the evidence indicating that as early as 1948, Epifanio Caro was aware of the adverse claim by the private respondents.
Analysis of the delay in asserting his rights and the implications of such delay on his claim.