Case Summary (G.R. No. 261292)
Legal Proceedings and Allegations
The case revolves around a dispute over the ownership of a parcel of land known as Lot 3-B, originally purchased by Doloreich Dumaluan from the heirs of Juan Dumaluan. Doloreich initiated a Complaint on June 6, 2005, for the declaration of the nullity of TCT No. 29414 issued to BRDI and sought reconveyance based on alleged defects in the title stemming from previous transactions involving the land that he claimed included Lot 3-B. Key issues included allegations of fraudulent sales by the Lorejos to Paulino Franco, which Doloreich contended voided subsequent transfers, including those to BRDI.
Regional Trial Court's Decisions
The Regional Trial Court (RTC) initially dismissed the case on October 20, 2015, on the grounds of lack of cause of action, affirmatively determining that BRDI, as a registered owner, was entitled to rely on the title in the absence of contrary evidence. Upon Doloreich's motion for reconsideration, the RTC altered its dismissal grounds to prescription in the order dated March 15, 2016, determining that Doloreich’s claim had already prescribed based on the ten-year limit applicable to actions for reconveyance due to fraud.
Court of Appeals' Reversal
The Court of Appeals (CA) granted Doloreich’s appeal on May 26, 2021, reversing the RTC’s orders and remanding the case for further proceedings. The CA identified Doloreich's complaint as an action for reconveyance based on the void nature of the sale between the Lorejos and Franco, emphasizing that the absence of a full trial to examine the claims deprived the court of sufficient facts to rule on prescription or on the merits.
Key Legal Issues Addressed
The CA articulated that matters regarding the validity of the earlier transactions, potential fraud, and whether Doloreich's action had prescribed required a full exploration of the facts during trial. The court underscored the necessity for a trial to ascertain if the sale was void, which would influence whether the action for reconveyance was imprescriptible—as actions based on fraud are subject to a ten-year prescription from the time of the adverse registration.
Supreme Court's Affirmation
The Supreme Court affirmed the CA's ruling, agreeing that the prescription issue could not be fully resolved without a trial. It clarified that while a case could be dismissed on grounds of prescription, the unique factual circumstances necessitated further factual determinations at trial. The court acknowledged that the nature of the action (i.e., reconveyance) significantly influenced the applicable prescriptive periods, referencing that actions based on the voidness of a sale are imprescriptible.
...continue readingCase Syllabus (G.R. No. 261292)
Case Background and Parties Involved
- Petitioner: Bohol Resort Development, Inc. (BRDI).
- Respondent: Doloreich Dumaluan (Doloreich).
- Case involves disputes over the ownership and registration of a parcel of land identified as Lot 3-B covered by Transfer Certificate of Title (TCT) No. 29414.
- Initial complaint filed by Doloreich before the Regional Trial Court (RTC) on June 6, 2005, seeking declaration of nullity of TCT No. 29414 and reconveyance with injunctive relief.
- Original case name: Doloreich Dumaluan v. Bohol Resort Development, Inc., PENRO-DENR Tagbilaran City, and Register of Deeds, Province of Bohol.
Facts of the Case
- Doloreich alleged purchase of Lot No. 5682 from Juan Dumaluan's heirs through a Deed of Extrajudicial Settlement with Simultaneous Sale.
- Discrepancy in lot area: Tax Declaration (TD) No. TM3-838 stated 23,971 sq.m. but Original Certificate of Title (OCT) No. 75904 granted only 16,298 sq.m.
- Doloreich discovered that Lorejo family members sold a portion of Lot 5682 (8,998 sq.m.) to Paulino Franco, which overlapped with Doloreich's land.
- Doloreich contended the sale by the Lorejos to Franco was void because the owners did not have authority and the lot area was misstated.
- Franco subdivided Lot 5682 into Lot 5682-A and Lot 5682-B; Lot 3-B derived from Lot 5682-A.
- The Spouses Uytengsu bought Lot 3-B from Franco and subsequently sold it to BRDI, who received TCT No. 29414.
- Doloreich asserted Lot 3-B is rightfully his and questioned the validity of the title issued to BRDI.
Allegations and Claims
- Doloreich alleged extrinsic fraud through subdivision and merging of lots by Franco to conceal true ownership.
- Contended that the Lorejos had no ownership and authority to sell to Franco.
- Asserted that the disputed sale voided the subsequent titles, necessitating reconveyance.
- Sought injunctive relief to stop BRDI’s construction activities on Lot 3-B.
BRDI's Defense and Counterclaims
- BRDI maintained that it is a registered owner of Lot 3-B with valid title (TCT No. 29414).
- Asserted bona fide purchase for value without knowledge of defects in prior transactions.
- Claimed Lorejos were rightful owners of undivided shares as heirs of Valentin Dumaluan.
- Explained discr