Case Digest (G.R. No. 93507)
Facts:
Heirs of Maria Revilleza Vda. de Vega and Heirs of Sebastian Salva Cruz v. Court of Appeals and Heirs of Antonio Tamisin, G.R. No. 93507, July 12, 1991, Supreme Court First Division, Medialdea, J., writing for the Court.The dispute concerns a parcel of land in Batong Malake, Los Baños, Laguna originally owned by Ignacio Revilleza, who died intestate leaving several children. An extrajudicial partition dated March 19, 1915 divided eight parcels among his heirs and Antonio Tamisin. A document titled “Escritura de Venta Absoluta,” dated October 8, 1921, allegedly executed by Antonio Tamisin and Maura Tamisin, purportedly sold one half of the land to Sebastian Salva Cruz and the other half to Lorenzo Revilleza. Antonio had joined the U.S. Navy circa 1917.
When Lorenzo died, his children pursued land registration; on May 20, 1929 Original Certificate of Title RO-1100 (No. 9423) issued in the names of Lorenzo’s heirs including Maria R. Vda. de Vega, covering 6,594 square meters. In 1950 Maria executed an affidavit of adjudication resulting in Transfer Certificate of Title No. 3911 in her name. Sebastian Salva Cruz declared the remainder of his portion for taxation and paid taxes from 1966 to 1979; a portion had been expropriated by NPC in 1941.
In 1964 the Bureau of Records Management certified that it could not locate the 1921 “Escritura de Venta Absoluta.” Antonio filed a criminal complaint for falsification against Sebastian but died in 1966 before prosecution. On July 20, 1973 private respondents (heirs of Antonio Tamisin) filed a complaint for annulment of documents, reconveyance and damages; an amended complaint filed October 14, 1974 alleged reconveyance and damages only. The heirs of Maria Vega and of Sebastian Salva Cruz answered; heirs of Maura Tamisin intervened.
The Regional Trial Court (June 4, 1986) dismissed the complaint and intervention for failure of plaintiffs and intervenors to prove their claims, and ordered the plaintiffs/intervenors to pay attorney’s fees. The Court regarded petitioners’ possession as acquisitive prescription and found plaintiffs/intervenors failed to identify the land adequately and failed to prove forgery of the 1921 deed. Only private respondents appealed.
The Court of Appeals reversed (November 13, 1989), holding that private respondents had identified the parcels described in the 1921 deed, that their action sought annulment of the alleged deed (an imprescriptible action under Article 1410 Civil Code) with reconveyance as a necess...(Subscriber-Only)
Issues:
- Did private respondents sufficiently identify the land they sought to recover?
- Was private respondents’ action one for annulment of contract (imprescriptible under Article 1410 Civil Code) or for reconveyance based on an implied/constructive trust (subject to prescription), and did ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)