G.R. No. 191128 - Guizano vs. Veneracion

Petitioners were Carmencita Guizano (now deceased), substituted by her heirs—Eugenio M. Guizano, Jr., Emmanuel M. Guizano, Edmund M. Guizano, Erwin M. Guizano, and Carmina M. Guizano—represented by their co-heir and attorney-in-fact Elmer Guizano, and Elmer M. Guizano.
Respondent was Reynaldo S. Veneracion.
The controversy involved two parcels of land in Barangay Kapihan, San Rafael, Bulacan that Lucia Santos (married to David Santos) and her brother Nicasio Bernardino inherited from their mother.
Nicasio sold his share, Lot No. 431 (consisting of 6,445 square meters), to Dr. Eugenio and his wife Carmencita.
The property was registered on February 22, 1985 under Transfer Certificate of Title (TCT) No. RT-18578 in the name of Emmanuel Guizano, the son of the Guizano spouses.
Lucia and her husband sold a 656-square-meter portion of their land in September 1995 to Reynaldo as the subject property.
Reynaldo’s purchase of the subject property required reliance on the Santoses’ representation that Lucia inherited the land from their parents since the Santoses had no documentary proof of ownership.

Before buying the subject property, Reynaldo’s father, Dr. Veneracion, hired a geodetic engineer to segregate the land being purchased from the land registered to Emmanuel.
Domingo Santos (son of the Santoses spouses), Nicasio, and Carmencita were present during the survey when Nicasio pointed out the boundaries of his former lot and Lucia’s share.
Carmencita also pointed out the boundaries of her property, marked by bamboo trees, a madre de cacao tree, and a pilapil.
The geodetic engineer drew up a sketch plan based on the survey, and all persons present, including Carmencita, affixed their signatures on it.
As an additional precaution during the execution of the deed of sale (*Bilihan ng Tuluyan*) in September 1995, the parties required Carmencita to affix her signature to the deed of sale under the heading Walang Tutol, signifying her non-objection to the sale.

After the sale, Carmencita discovered that the property sold to Reynaldo was actually part of the property already registered under Emmanuel’s name under TCT No. RT-18578 (registered February 22, 1985).
Carmencita then placed the word HOLD on the subdivision plan signed by the geodetic engineer.

On June 14, 1999, Reynaldo filed a complaint against Carmencita and the Santos spouses, praying that Carmencita, as owner or as lawful attorney-in-fact of her son Emmanuel, be ordered to reconvey the 656-square-meter parcel of land to Reynaldo.
The complaint was docketed as Civil Case No. 623-M-99 and raffled to Branch 81 of the RTC of Malolos, Bulacan.
Carmencita, in her Answer, claimed lack of merit because the property subject of the sale between Reynaldo and the Santos spouses was part of the property owned and registered in the name of her son Emmanuel under TCT No. RT-18578.
Carmencita also argued in effect that Reynaldo had no cause of action against her.
Carmencita raised the defect that the case was not properly directed against Emmanuel as a real party in interest, and she repeatedly raised this defect before the lower court in her Answer and Pre-Trial Brief.

On July 24, 2002, the RTC dismissed Reynaldo’s complaint for lack of merit.
The RTC found that although the sale between the Santoses and Reynaldo was established, Reynaldo failed to show that the Santoses had the legal right to sell the lot.
The RTC observed that the property sold to Reynaldo was already covered by TCT No. RT-18578 registered in Emmanuel’s name.
The RTC found that the Santoses presented no evidence of ownership because they never had the property surveyed, never paid real estate taxes on it, and never declared it for tax.
The RTC held that Emmanuel’s title had already attained indefeasibility at the time Reynaldo filed his action.
The RTC also held that even if an action for reconveyance had not yet prescribed because Reynaldo remained in possession, Reynaldo was guilty of laches for filing the action fourteen years after Emmanuel’s title had been issued.

On appeal, the CA reversed the RTC in a decision dated July 31, 2007, ordering Carmencita to reconvey the subject property to Reynaldo.
The CA observed Carmencita’s acts and representations, including that she told Dr. Veneracion that the small portion adjacent to his property did not belong to her but belonged to Lucia.
The CA found that in the absence of documents showing the technical description of the shares of Nicasio and Lucia, Lucia and her son Domingo built an earthen dike and planted trees to demarcate the boundary, and that boundary was respected even when Carmencita’s family bought the property from Nicasio.
The CA found that Carmencita participated in the survey, pointed out the boundaries of her lot, and signed the deed of sale to signify her conformity to the sale.
The CA concluded that from Carmencita’s acts and representations, it was clear she believed the subject property belonged to the Santoses, and she was estopped...(Subscriber-Only)

Whether Reynaldo’s complaint failed for being directed against a party not shown to be the real party in interest, considering that the subject property was registered in Emmanuel’s name under TCT No. RT-18578

Whether an action for reconveyance binds only parties properly impleaded in an action in personam.
Whether Carmencita, even if treated as attorney-in-fact, was the proper party to be sued for reconveyance as the real party in interest.
Whether Emmanuel should have been impleaded as defendant, given that Torrens title showed ownership in Emmanuel’s name.

Whether reconveyance could be granted despite arguments on indefeasibility and laches, and despite the estoppel theory accepted by the CA

Whether Emmanuel’s certificate of title had attained indefeasibility and was no longer open to review on grounds of actual fraud.
Whether the Santoses’ delay and the passage of fourteen years constituted laches barring the action for reconveyance.
Whether estoppel based on Carmen...(Subscriber-Only)