Case Digest (G.R. No. 71110)
Facts:
The case involves petitioners Paz Villagonzalo, Estela Villagonzalo, Aida Villagonzalo, Herminia Villagonzalo, Gwendolyn Villagonzalo, Jensine Villagonzalo, and Leonila Villagonzalo against respondents Intermediate Appellate Court and Cecilia A. Villagonzalo. The events leading to the case began on February 22, 1961, when Juan C. Villagonzalo, the father of the petitioners, purchased Lot No. 7429 of the Ormoc Cadastre, located in Barrio Dolores, Ormoc City, for P1,500. The purchase was made from the heirs of Roman Matuguina, but the title was registered in the name of Cecilia A. Villagonzalo, Juan's daughter, who was single at the time. This arrangement occurred because Juan borrowed P500 from Cecilia to complete the payment for the lot. Consequently, Transfer Certificate of Title No. 4259 was issued in Cecilia's name on July 18, 1962.
The petitioners filed a complaint for reconveyance on April 2, 1975, thirteen years after the issuance of the title. The Court of F...
Case Digest (G.R. No. 71110)
Facts:
Purchase of the Property: On February 22, 1961, Juan C. Villagonzalo, the predecessor-in-interest of the parties, purchased Lot No. 7429 of the Ormoc Cadastre, situated at Barrio Dolores, Municipality of Ormoc, containing an area of 97,213 sq. meters, from the Heirs of Roman Matuguina for P1,500.00. The sale was made to appear in the name of his daughter, Cecilia Villagonzalo, who was single, as he borrowed P500.00 from her to complete the payment.
Issuance of Title: On July 18, 1962, Transfer Certificate of Title No. 4259 was issued in the name of Cecilia A. Villagonzalo as the registered owner.
Filing of the Complaint: The complaint for reconveyance was filed on April 2, 1975, thirteen (13) years after the issuance of the title in Cecilia's name.
Trial Court Decision: The Court of First Instance of Leyte ruled in favor of the plaintiffs (petitioners), declaring the lot as conjugal property of the deceased spouses Juan Villagonzalo and Felicisima Abella Villagonzalo. The court ordered the cancellation of Cecilia's title and the issuance of a new title in the name of the deceased spouses, with the land to be partitioned among the heirs.
Appeal to Intermediate Appellate Court: Cecilia appealed to the Intermediate Appellate Court, which reversed the trial court's decision and dismissed the complaint for reconveyance, holding that the action had prescribed and that the petitioners were guilty of laches.
Issue:
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Ruling:
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Ratio:
Prescription of Action for Reconveyance: An action for reconveyance based on an implied or constructive trust prescribes in ten years from the date adverse title is asserted. This is because such an action is based on an obligation created by law, and the Civil Code provides that such actions prescribe in ten years.
Laches as a Bar to Action: Laches is a valid defense in actions to enforce implied trusts. Even if the trust is resulting or constructive, its enforcement may be barred by laches if the claimant fails to assert their rights for an unreasonable period of time, causing prejudice to the adverse party.
Adverse Title and Repudiation of Trust: The issuance of a title in the name of a person other than the rightful owner constitutes an assertion of adverse title and repudiates any implied trust. The registration of the title serves as constructive notice to all parties, and the ten-year prescriptive period begins to run from the date of such registration.
Conclusion:
The Supreme Court held that the petitioners' action for reconveyance was barred by both prescription and laches. The issuance of the title in Cecilia's name in 1962 was a clear assertion of adverse title, and the petitioners' failure to act for thirteen years constituted laches. The decision of the Intermediate Appellate Court dismissing the complaint was therefore affirmed.