G.R. No. L-39047 - Pascua vs. Florendo

The petitioners—Alberto Pascua, Crispina Pascua, Sotera Pascua, and Eduardo Molina—filed a complaint for reconveyance with damages against the private respondents, spouses Clemente and Juliana Castro.
The subject matter is a parcel of land located in Dacalafugo, Camalaniugan, Cagayan, which was inherited from the deceased parents of the petitioners.

The land, measuring 1.02–20 hectares and described in paragraph 3 of the complaint, was originally acquired by the parents (Jordan Pascua and Magdalena Dumadag) who had five children.
The petitioners contend that their deceased brother, Martin Pascua, fraudulently sold the entire property—when he was only entitled to one-fifth—leaving the petitioners deprived of their rightful shares.
Evidence was presented showing:

The alleged sale was effected by Martin Pascua on May 8, 1951, in favor of Clemente Castro (and indirectly benefiting Juliana Castro), as indicated by Exhibit D.
Discrepancies in signatures in Exhibit D, with the genuine signatures provided in Exhibits E and other supporting documents, pointed to forgery or misrepresentation.
The petitioners never consented to the sale and had not appeared before the Notary Public when the deed was executed.

The respondents, instead of filing an answer, filed a motion to dismiss the complaint on the ground that it stated no cause of action and that the action was time-barred by the statute of limitations.

Initially, the trial court denied the respondents’ motion on the basis that the prescription issue did not appear on the face of the complaint.

Subsequent to denying the motion, the trial court declared the respondents in default for failing to file an answer within the prescribed period, and it proceeded to receive the petitioners’ evidence ex-parte.
Based on the evidence adduced:

It was found that the petitioners had full knowledge of the sale transaction, given their long-standing proximity and relationship with the respondents.
The court noted that the petitioners had been deprived of the fruits of the land for more than 20 years, and that the defendants had maintained possession during that period.
The evidence also highlighted that the original deed of sale dated from 1951, whereas the petition was filed only on May 31, 1973—22 years later.

Dismissing the case on the ground of prescription despite previously denying a motion to dismiss based on the same ground.
Not granting the relief prayed for, even though the defendants were declared in default.

They argued that the prescription period should be computed from the time they discovered the fraud (allegedly in 1973) rather than from the date the deed was executed in 1951.
The petitioners anchored a secondary contention on the interpretation of Rule 18, Section 1 of the Rules of Court, asserting that default should automatically entitle them to the relief claimed.

Whether the trial court erred in dismissing the case on the ground that the action for reconveyance had prescribed, considering that the deed of sale was executed in 1951 and the complaint was filed in 1973.
Whether the statute of limitations should be computed based on the petitioners’ alleged discovery of the fraud in 1973 rather than from the execution date of the deed.

Whether the trial court erred in not granting the relief prayed for, given that the respondents were declared in default for failing to file an answer.
Whether a declaration of default under Rule 18 automatically entitles the plaintiff to a judgment in the full relief demanded, or if the court must still assess the sufficiency of the evidence.