G.R. No. 138971 - Philippine Economic Zone Authority vs. Ferdez

The subject property is Lot No. 4673 of the Opon Cadastre in Lapu-Lapu City, with an area of approximately 11,345 square meters.
Originally covered by Original Certificate of Title (OCT) No. RO-2537 (May 19, 1982), the lot was registered in multiple names including Florentina Rapaya, Victorino Cuizon, and several other co-heirs.
On May 15, 1982, Jorgea Igot-SoroAo, Frisca Booc, and Felix Cuizon executed an Extrajudicial Partition, declaring themselves as the surviving heirs. They subsequently received Transfer Certificate of Title (TCT) No. 12467 on July 8, 1982.

The property was one of the objects of expropriation proceedings (Civil Case No. 510-L) pending before Branch XVI of the RTC of Lapu-Lapu City.
On August 11, 1982, the RTC approved a Compromise Agreement between the Export Processing Zone Authority (EPZA) and the new registered owners as a resolution to the expropriation proceedings.
Following the approved Compromise Agreement, petitioner (PEZA) acquired title to Lot No. 4673 via TCT No. 12788 issued on October 13, 1982.

On July 29, 1996, private respondents (the heirs of the deceased spouses Juan Cuizon and Florentina Rapaya) filed a Complaint for Nullity of Documents, Redemption, and Damages against petitioner and others in the RTC (Civil Case No. 4534-L).
The complaint alleged exclusion from the extrajudicial settlement and targeted the nullification of several documents, including TCT No. 12788, which was issued in petitioner’s name.
Petitioner responded by filing a Motion to Dismiss the Complaint on February 17, 1997, on grounds of prescription which was subsequently denied by the RTC on January 12, 1998.
A Motion for Reconsideration was also filed by petitioner and denied on March 31, 1998.

On April 30, 1998, petitioner elevated the issue to the Court of Appeals through a Petition for Certiorari.
The Court of Appeals, reaffirming the RTC’s orders, dismissed petitioner’s petition and held that no abuse of discretion was committed by the lower court.
The CA Decision, in substance, found that the private respondents’ action—conceived as reconveyance of property—could proceed where fraud was involved, notwithstanding the lapse of time under certain equitable doctrines.

Whether the appellate court erred in not holding that private respondents’ claim against the expropriated property had prescribed.
Consideration of the two-year period for an unduly excluded heir to seek a new settlement and the implications of constructive notice via registration.

Whether the appellate court erred in not holding that an action for reconveyance does not lie against property that has already been conveyed to an innocent purchaser for value.
Examination of the prescription periods applicable to equitable remedies, including actions based on fraud, implied trust, or constructive trust.