Facts:

The case involves Severina Marabilles and her child as plaintiffs and Alejandro Quito and Aida Quito as defendants. The action was initiated in the Court of First Instance of Camarines Sur for the recovery of an 18-hectare parcel of land located in Pili, Camarines Sur. The defendants did not respond to the complaint but instead filed a motion to dismiss on three grounds: (1) the plaintiffs lacked legal capacity to sue, (2) the complaint failed to state a cause of action, and (3) the action had prescribed. The defendants supported their motion with two documents: Annex A, which was Transfer Certificate of Title No. 1065 issued to Guadalupe Saralde on March 31, 1941, and Annex B, Original Certificate of Title No. 1018 issued to Patricio Marabiles on February 19, 1954. The latter was a homestead patent granted under Act No. 2874. The plaintiffs opposed the motion, but the court issued an order on November 8, 1954, granting the motion and dismissing the complaint with costs again...

Facts:

1. Parties Involved:

   • Plaintiffs and Appellants: Severina Marabiles and her child.
   • Defendants and Appellees: Alejandro Quito and Aida Quito.

2. Subject Matter:

   • The case involves a parcel of land consisting of 18 hectares located in Pili, Camarines Sur.

3. Title and Ownership Claims:

   • Defendants filed a motion to dismiss the complaint, attaching two titles:
     • Annex A: Transfer Certificate of Title No. 1065 issued in the name of Guadalupe Saralde on March 31, 1941.
     • Annex B: Original Certificate of Title No. 1018 issued in the name of Patricio Marabiles on February 19, 1954, under a homestead patent granted under Act No. 2874.

4. Grounds for Motion to Dismiss:

   • Plaintiffs lack legal capacity to sue.
   • The complaint states no cause of action.
   • The action has prescribed.

5. Lower Court Decision:

   • The Court of First Instance of Camarines Sur dismissed the complaint on November 8, 1954, agreeing with the defendants' motion to dismiss.

6. Appeal:

   • Plaintiffs appealed to the Court of Appeals, which certified the case to the Supreme Court due to the purely legal nature of the issues raised.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Legal Capacity to Sue:

   • The property of a deceased person automatically vests in the heirs by operation of law upon the death of the predecessor. Heirs can assert their rights without a prior judicial declaration of heirship.

2. Cause of Action:

   • In determining the sufficiency of a cause of action, only the facts alleged in the complaint are considered. The relationship between Guadalupe Saralde and the defendants, as alleged, establishes a legal basis for the action.

3. Prescription and Constructive Trust:

   • When property is acquired through fraud, a constructive trust is created in favor of the defrauded party. The defense of prescription does not apply in such cases, as the defrauded party has the right to recover the property regardless of the lapse of time.

Concurring Opinion

• Justice J.B.L. Reyes concurred with the majority but expressed reservations about the broad statement that property held under constructive trust can be vindicated regardless of the lapse of time. He noted that constructive trusts, unlike express or resulting trusts, do not require repudiation for prescription to apply. However, in this case, there was no clear evidence of when the fraud was discovered, so prescription could not be definitively applied.

Conclusion:

• The Supreme Court set aside the lower court's order dismissing the complaint and remanded the case for further proceedings. Costs were imposed on the appellees (defendants).