Title
Lopez vs. Court of Appeals
Case
G.R. No. 157784
Decision Date
Dec 16, 2008
A dispute over properties excluded from a trust estate leads to the dismissal of a petition for reconveyance due to the expiration of the prescriptive period.
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Case Digest (G.R. No. 157784)

Facts:

  • The case involves Richard B. Lopez v. Court of Appeals (G.R. No. 157784).
  • Richard B. Lopez served as the trustee for the Trust Estate of the late Juliana Lopez-Manzano.
  • The dispute centers on 1,500 hectares of land that were allegedly excluded from the trust estate.
  • Juliana executed a notarial will on March 23, 1968, which established a trust fund for her paraphernal properties.
  • Her husband, Jose Lopez Manzano, was appointed executor of her estate after her death shortly after the will was executed.
  • The probate court admitted Juliana's will and approved an inventory of her properties, excluding the disputed lands from the Fideicomiso.
  • Following Jose's death in 1980, he left a holographic will that bequeathed the disputed properties to several respondents.
  • The properties were transferred to the respondents after the probate of Jose's will.
  • In December 1984, Richard B. Lopez was appointed as the trustee and subsequently filed for reconveyance of the disputed properties.
  • The Regional Trial Court (RTC) dismissed his case due to prescription, a decision that was later affirmed by the Court of Appeals.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the petition for reconveyance had indeed prescribed, thereby affirming the decision of the Court of Appeals.
  • The Court concluded that the fiduciary relationship...(Unlock)

Ratio:

  • The Supreme Court's decision emphasized the nature of the trust and the relevant prescriptive period.
  • The disputed properties were excluded from the Fideicomiso, which created a presumption of regularity in the probate process.
  • The registration of the properties in Jose's name was upheld as valid.
  • The action for reconveyance was subject to a ten-year prescriptive period, commencing from September 15, 1969.
  • The Court clarified that in cases of constructive trust, the prescriptive period can begin without explicit repudiation by ...continue reading

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