Case Summary (G.R. No. 52064)

Background of the Case

• The case involves a dispute over a 3,732 square-meter portion of land located in Calasiao, Pangasinan, which is part of a larger parcel of 8,752 square meters covered by Original Certificate of Title No. 63.
• The title was issued in the name of Mariano M. de Vera, who died in 1951 without any heirs.
• The estate was administered first by his widow and later by Salvador Estrada, the private respondent in this case.
• Juliana Caragay-Layno, the petitioner, is a first cousin of the deceased and claims ownership of the disputed land, asserting that it belonged to her father, Juan Caragay.

Proceedings and Claims

• Estrada demanded that the petitioners vacate the disputed land, asserting that it was titled in de Vera's name.
• The petitioners resisted, claiming that the land was theirs and had been wrongfully included in the title.
• Juliana counterclaimed for reconveyance, arguing that an implied or constructive trust existed in her favor due to the alleged fraudulent inclusion of the land in the title.

Trial Court's Decision

• The Trial Court ruled in favor of Estrada, ordering Juliana to vacate the disputed portion.
• Juliana appealed the decision, contesting the finding that her claim for reconveyance had prescribed under the law.

Appellate Court's Findings

• The Appellate Court affirmed the Trial Court's decision, stating that Juliana's claim for reconveyance was barred by the ten-year prescription period.
• The court noted that the title had become indefeasible due to the lapse of time since its registration.

Evidence of Possession

• Evidence presented showed that the disputed portion had been possessed openly and continuously by Juan Caragay and later by Juliana for approximately 45 years.
• Juliana had declared the property under her name and paid taxes on it from 1938 to 1972, demonstrating her claim of ownership.

Allegations of Fraud

• Juliana claimed that de Vera had borrowed her tax declaration to use as collateral, leading to the fraudulent inclusion of the disputed land in the title.
• The court found that there was no evidence of adverse possession or claim by de Vera or his successors during his lifetime, which contributed to the conclusion of laches against them.

Conclusion on Title and Ownership

• The court determined that the inclusion of the disputed portion in the title was void due to the lack of any claim of ownership by de Vera or his estate.
• The evidence suggested that the discrepancy in the area of the land indicated that the disputed portion did not form part of de Vera's estate.

Legal Principles Applied

• The court emphasized that mere possession of a title does not equate to true ownership, especially when the property was...continue reading

Case Syllabus (G.R. No. 52064)

Case Background

• The case involves a dispute over a 3,732 square meter portion of land owned by the deceased Mariano de Vera, which is part of a larger parcel of land.
• The entire parcel, covering 8,752 square meters, is situated in Calasiao, Pangasinan, and is registered under Original Certificate of Title No. 63.
• The land was originally registered in the name of Mariano de Vera, who passed away in 1951 without any heirs.
• Juliana Caragay-Layno, the petitioner, is a first cousin of de Vera and claims ownership to the disputed portion based on her family's historical possession of the land.

Procedural History

• The Court of First Instance of Pangasinan ruled that Salvador Estrada, as the administrator of de Vera's estate, was entitled to recover possession of the disputed land, leading to Juliana's appeal to the Court of Appeals, which affirmed the lower court's decision.
• Juliana claimed that the land had been wrongfully included in de Vera's title and sought reconveyance based on an implied or constructive trust.

Key Findings of the Trial Court

• The trial court ruled against Juliana, stating that her claim for reconveyance had prescribed after ten years, referencing applicable jurisprudence.
• The court emphasized that de Vera's title had become indefeasible due to the lapse of time without any adverse claim being made against i...continue reading