Case Digest (G.R. No. 200558) Core Legal Reasoning
Core Legal Reasoning
Facts:
In Consuelo V. Pangasinan and Annabella V. Borromeo v. Cristina Disonglo-Almazora et al., petitioners are the substituted heirs of Aurora Morales-Vivar, sole heir of Aquilina Martinez, original registered owner of a 572-sqm parcel in Brgy. Sto. Domingo, Biñan, Laguna (TCT No. T-18729, July 29, 1939). After World War II, Aquilina and her grandmother entrusted the owner’s duplicate title to their relative, Conrado Almazora, to rebuild their home in Tondo, Manila. Conrado’s family occupied the Laguna land. Aquilina died in 1949 and Aurora inherited the property (TCT No. T-35280). Conrado died in 1972. In 1994 Aurora learned from Conrado’s widow that the land had been fraudulently transferred to Conrado and sold to Fullway Development Corp. for ₱4,000,000. She demanded the proceeds in 1995 but was ignored. On May 9, 1996, Aurora sued Conrado’s heirs for damages, alleging breach of trust, fraud and seeking restitution of the sale proceeds. The Regional Trial Court dismissed the compl Case Digest (G.R. No. 200558) Expanded Legal Reasoning
Expanded Legal Reasoning
Facts:
- Parties, property, and antecedents
- Petitioners: Consuelo V. Pangasinan and Annabella V. Borromeo, substituted heirs of Aurora Morales-Vivar (Aurora), original plaintiff; Respondents: heirs of Conrado Almazora—Cristina Disonglo-Almazora (widow), Renilda Almazora-Casubuan, Rodolfo Casubuan, Susana Almazora-Mendiola, Carlos Mendiola, Cecilio Almazora, and Nenita Almazora.
- Subject property: 572-sq.m. parcel in Brgy. Sto. Domingo, Biñan, Laguna; originally under TCT No. T-18729 in the name of Aquilina Martinez (issued July 29, 1939).
- Post-war events: After Manila’s liberation (1945), Aquilina and her maternal grandmother, Leoncia Almendral, borrowed funds from relative Conrado Almazora to rebuild their war-damaged Tondo house; in return, Leoncia entrusted to Conrado the owner’s duplicate of TCT No. T-18729; Conrado’s family continued staying on the Biñan property.
- Succession chain: Aquilina died July 19, 1949; TCT No. T-18729 cancelled and replaced by TCT No. T-35280 in the name of her sole heir, Aurora.
- Transfers, conveyances, and later discovery
- Conveyance to Conrado: On June 17, 1965, title was transferred to Conrado under TCT No. T-35282 by virtue of an “Adjudication and Absolute Sale of a Parcel of Registered Land” dated January 9, 1949, purportedly signed by Aurora and her husband.
- Subsequent events: Conrado died on February 7, 1972; title later transferred to Conrado’s heirs under TCT No. T-114352; heirs sold the property to Fullway Development Corporation for P4,000,000.00.
- Discovery and demands: In 1994, Aurora learned from Cristina that title had long been transferred to Conrado and that the property had been sold to Fullway; Aurora sent demand letters dated October 30, 1995 and March 5, 1996 seeking turnover of the sale proceeds; demands were unheeded.
- Litigation history
- Complaint: On May 9, 1996, Aurora and her husband Arturo filed a damages suit (Civil Case No. 96-0206) before RTC Parañaque, Branch 259, alleging that Conrado received the owner’s duplicate of title only for safekeeping; that Conrado’s family had stayed on the land since 1912 with permission; that Conrado refused to return the title; that the conveyance and transfers were unauthorized and fraudulent; and that damages were due.
- Answer: Respondents asserted valid transfers—TCT No. T-35282 (Conrado) to TCT No. T-114352 (heirs), sale to Fullway; denied fraud; raised defenses including failure to state a cause of action and prescription; sought preliminary hearing on affirmative defenses.
- Interlocutory review: RTC (Order, May 27, 1999) held complaint stated a cause of action; respondents’ certiorari to CA denied (Decision, February 24, 1999), CA characterizing action as one for damages arising from fraud of trustee against cestui que trust and not prescribed on the face of the complaint; trial proceeded.
- RTC judgment on the merits (June 29, 2004): Complaint dismissed; court found Aurora failed to prove right to the property; found laches; recognized the 1949 deed as basis for the 1965 transfer to Conrado; noted petitioners offered no convincing evidence to controvert signatures or otherwise establish fraud; denied damages.
- Appeal: Aurora appealed; after Aurora’s death (March 26, 2008), her children (including petitioners) were substituted (CA Resolution, July 15, 2010).
- CA Decision (July 28, 2011): Affirmed RTC; held petitioners barred by laches; action also prescribed—10 years from registration in Conrado’s name (June 17, 1965), expiring June 17, 1975; suit filed only May 9, 1996; MR denied (Resolution, February 3, 2012).
- Supreme Court: Petition for review on certiorari (Rule 45) filed by petitioners raising errors on laches, prescription, and validity of Conrado’s acquisition; respondents argued laches and lack of merit.
Issues:
- Procedural and substantive issues
- Whether the Rule 45 petition, raising laches, prescription, and bad faith findings, presents reviewable questions of law or impermissible questions of fact.
- Whether petitioners’ claims are barred by laches given the decades-long inaction despite knowledge of respondents’ possession and title.
- Whether the action is barred by prescription, and specifically whether Section 47 of P.D. No. 1529 precludes prescription against the registered owner versus the 10-year period under Article 1144 for reconveyance based on implied/constructive trust (Article 1456).
- Whether fraud by Conrado was proven by clear and convincing evidence sufficient to establish an implied trust and support an award of damages.
- Whether petitioners established ownership or entitlement to relief, including damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)