Title
Pascua vs. Copuyoc
Case
G.R. No. L-9595
Decision Date
Nov 28, 1958
Juan Pascua's heirs fraudulently registered land in 1929, excluding plaintiffs Pedro and Andres Pascua. Plaintiffs sought annulment of titles and transactions, alleging fraud. Court remanded case to assess validity of claims.

Case Digest (G.R. No. 252720)
Expanded Legal Reasoning Model

Facts:

  • Basic Property and Registration Details
    • The subject matter is Lot No. 2986 of the Cadastral Survey of Guimba, Cadastral Case No. 23, G.L.R.O. Record No. 401, situated in barrio Nagpandayan, municipality of Guimba, Nueva Ecija.
    • The parcel covers an area of approximately 43,256 square meters.
  • Historical Chain of Title and Transactions
    • During the Spanish regime, Juan Pascua, the grandfather of the plaintiffs Pedro Pascua and Andres Pascua, was the owner of the parcel.
    • On February 2, 1900, in a private instrument, Juan Pascua donated the land to the spouses Victoriano Pascua and Bonifacia Lora.
    • On January 31, 1929, via public instrument registered in the Registry of Deeds, the spouses sold one-half of the land to Andres Pascua.
    • On March 2, 1936, for the consideration of the marriage between Pedro Pascua and Luisa Corpuz, the spouses donated the remaining half of the land to Pedro Pascua, with the donation duly accepted.
    • On June 14, 1939, Pedro Pascua and Andres Pascua partitioned the property, with delineation of the eastern and western halves, and subsequent possession by the respective parties.
    • Payment of the land tax was continuously made by the parties from 1900 to the present time.
  • Cadastral Proceedings and Reconveyance
    • On October 31, 1929, in cadastral proceedings at the Court in Guimba, the title registration was decreed in favor of the heirs of the late Juan Pascua, listing several persons with specified ages and familial relationships.
    • In April 1940, Andres Pascua and Pedro Pascua discovered the decree and demanded reconveyance of the property from the defendants (heirs and successors-in-interest).
    • Between April 21, 1940, and January 12, 1941, multiple deeds of reconveyance were executed by various defendants (including Angelo Reyes, Severina Pascua, Pedro Pascua in his earlier capacity, and Marcelo Baltazar as guardian ad litem for minors).
    • On June 12, 1940, the appellants filed a petition before the Cadastral Court to review the prior decision and to have the parcel adjudicated in their favor, with notice served to several parties, though only a few objected.
  • Subsequent Land Registration and Transfer Transactions
    • On March 31, 1952, certain defendants (including Marta Manuel, Pedro Pascua, Angelo Reyes, Severina Pascua, Flaviano Baltazar, and Quintin Melebo) moved the court to issue a decree for registration of the land in favor of the heirs of Juan Pascua.
    • On June 18, 1952, the General Land Registration Office issued Decree No. 7264, and on July 7, 1952, an original certificate of title (O-680) was issued in the name of the heirs.
    • In August 1952 and subsequent months, a series of sales, donations, and cancellations of titles occurred:
      • Pedro Pascua and Angelo Reyes sold their shares to Marta Manuel on August 3, 1952.
      • Flaviano Baltazar and Virginia Baltazar donated their interests to Marta Manuel on the same date.
      • Severina Pascua sold her share to Marta Manuel on March 12, 1953, followed by the issuance and later cancellation of certificates/titles leading to new titles in the name of Marta Manuel, Quintin Melebo, and eventually Mariano Copuyoc by March 1954.
  • Allegations of Fraud and Wrongful Transactions
    • The plaintiffs allege that the series of transactions (sales, donations, and reissuance of certificates) were fraudulent.
    • It is contended that the defendants, particularly Quintin Melebo and Mariano Copuyoc—who are attorneys—acted with knowledge that the original registered owners and their successors did not truly own any valid interest in the parcel.
    • The fraudulent design was aimed at depriving the plaintiffs of their rightful property.
  • Pleas, Counterclaims, and Procedural History
    • The plaintiffs seek annulment of the fraudulent transactions, nullity of related decrees and titles (including Decree No. 7264, various deeds, and certificates of title), and ultimately demand the issuance of a proper decree and title in their names.
    • Defendants Quintin Melebo and Mariano Copuyoc filed answers denying the allegations and asserting that they were innocent purchasers relying on valid certificates of title.
    • Mariano Copuyoc raised the issue that the review of the decree was barred by the lapse of more than one year since its issuance.
    • Counterclaims were raised by the defendants:
      • Quintin Melebo claimed damages of ₱10,000 for alleged defamation affecting his professional and business reputation.
      • Mariano Copuyoc sought ₱50,000 and additional damages for alleged malicious statements and forcible possession actions by the plaintiffs.
    • The Solicitor General, for the Insular Treasurer, contested several allegations and maintained that the plaintiffs had no valid right or interest in the land, also asserting that the action for recovery of damages from the Assurance Fund was barred as well as precluded by the primary cause of action.
    • On May 18, 1955, Quintin Melebo filed a motion to dismiss on the ground that the reopening of the registration decree was barred by the statute of limitations (more than one year had elapsed from issuance).
    • The trial court, on June 7, 1955, granted the motion to dismiss, which led the plaintiffs to appeal the dismissal.

Issues:

  • Whether the dismissal of the plaintiffs’ complaint on the ground of the lapse of the one-year period for reviewing the cadastral decree is proper, considering the proper application of the statute of limitations.
  • Whether the defense of prescription (lapse of time) was properly raised by Quintin Melebo in his answer, and if not, whether such defense is waived pursuant to Section 8, Rule 26 of the Rules of Court.
  • Whether the series of fraudulent transactions (sales, donations, and reissuances of titles) can be annulled and set aside despite the lapse period affecting the decree issued by the General Land Registration Office.
  • Whether the plaintiffs are entitled to reconveyance or cancellation of the allegedly fraudulent transactions, thereby restoring their title and rights in the parcel of land.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.