G.R. No. 93507 - Heirs of Vda. de Vega vs. Court of Appeals

Case Summary (G.R. No. 93507)

Factual Background

Ignacio Revilleza, the original owner of the land, died intestate and left five children: Margarita, Lorenzo, Florencio, Sinforosa, and Dominga, all surnamed Revilleza. Margarita had two children with Valeriano Tamisin: Antonio and Maura, both surnamed Tamisin. Antonio was the father of the private respondents Paulino, Lorenza, Virginia, Cristeta, Emilia, Bethilda, and Dorotea (all surnamed Tamisin). Maura was the mother of certain intervenors, namely Marciana, Lucio, Placida, Susana, Carmen, and Melencio, all surnamed Dequillo.

Lorenzo Revilleza had four children: Emilio, Macario, Marcela, and Maria R. Vda. de Vega. Maria died on April 1, 1979, leaving five children, including Gloria Vega Yap, Marcos, Jr., Rogelio, Lubin, and Carlos. Sebastian Salva Cruz was the son of the other daughter of Ignacio Revilleza. Sebastian died on July 24, 1974, leaving behind the other petitioners.

After Ignacio’s death, an Extrajudicial Partition dated March 19, 1915 was executed among Florencio, Lorenzo, Sinforosa, and Dominga Revilleza and Antonio Tamisin. The partition distributed eight parcels of land, including parcels located at Batong Malake, Los Baños, Laguna, to Lorenzo, Florencio, Sinforosa, Dominga, and also a parcel to Antonio Tamisin. The partition was recorded in the Notarial Register of Miguel Bonifacio, as shown by a certified National Archives copy.

Sometime in 1917, Antonio Tamisin joined the U.S. Navy. On October 8, 1921, a document denominated “Escritura de Venta Absoluta” was allegedly executed and signed by Antonio Tamisin and Maura Tamisin, with Julio Dequillo shown as having provided conformity. The document allegedly conveyed one-half of the land to Sebastian Salva Cruz and the other half to Lorenzo Revilleza. The portion allegedly conveyed to Sebastian had an area of 1,611 square meters, 435 square meters of which were expropriated by the National Power Corporation in July 1941. From 1948, Sebastian declared the remaining area for taxation, and he paid realty taxes from 1966 to 1979. The land was surveyed for him by Geodetic Engineer Danilo Angeles, who also prepared the plan and technical description.

When Lorenzo Revilleza died on May 15, 1928, his son Emilio Revilleza filed an application for registration of the second half of the land, docketed as Case No. 1469 under the G.L.R.O. Record No. 32505. As a result, on May 20, 1929, Original Certificate of Title RO-1100 (No. 9423) was issued in the names of Emilio, Macario, and Marcela, all surnamed Revilleza, and Maria R. Vda. de Vega, covering a tract at Batong Malake with an area of 6,594 square meters.

On April 18, 1950, Maria R. Vda. de Vega executed an Affidavit of Adjudication which adjudicated the land covered by OCT RO-1100 (No. 9423) to her, resulting in Transfer Certificate of Title No. 3911. In 1964, private respondents obtained a certification from the Bureau of Records Management indicating that the archives failed to reveal the existence of the Deed of Sale (“Escritura de Venta Absoluta”) alleged to have been executed by Antonio Tamisin. Antonio Tamisin then filed a criminal complaint against Sebastian Salva Cruz for falsification of documents, but it was not pursued because Antonio later became sick and died on November 2, 1966.

On July 20, 1973, private respondents filed a complaint for annulment of documents, reconveyance, and damages against petitioners. On October 14, 1974, they filed an amended complaint limiting the relief to reconveyance and damages. Petitioners’ heirs of Maria filed an answer on January 28, 1975, while the heirs of Sebastian filed an answer on July 1, 1975. A complaint-in-intervention was filed on February 4, 1976 by the heirs of Maura Tamisin.

Trial Court Proceedings

On June 4, 1986, the Regional Trial Court rendered judgment dismissing both the complaint and the complaint-in-intervention for failure to prove the claims by a preponderance of evidence. The trial court also ordered plaintiffs and intervenors to pay attorney’s fees in specified amounts to the respective sets of defendants and to pay costs.

The trial court’s dismissals were anchored on several factual and legal conclusions. It held that the evidence submitted by private respondents and intervenors to prove identity of the land was inadequate, particularly for Maria R. Vda. de Vega’s portion, because the sketches prepared by Engineer Ruperto Coquia were based on verbal information supplied by Dorotea T. Gonzales, who was not even born at the time Antonio Tamisin inherited the property, and because Engineer Coquia did not conduct an actual physical survey, relying instead on documents not shown to be properly authenticated. It further ruled that Maria and her successors had been in public, peaceful, and continuous possession from the issuance of OCT RO-1100 on May 20, 1929 up to the filing of the original complaint, and thus had become owners by acquisitive prescription under Article 1137 of the Civil Code.

The trial court also found the action barred by prescription. It reasoned that private respondents and intervenors failed to show any document proving the alleged trust, that there was insufficient evidence to show forgery of Antonio Tamisin’s signature on the “Escritura de Venta Absoluta,” and that, as it was a notarized document, the presumption of regular performance by the notary should be maintained in the absence of contrary evidence. It added that under both ordinary and extraordinary prescription, Sebastian Salva Cruz must be considered the owner of the land in question, invoking Articles 1134 and 1137.

Parties’ Contentions on Appeal and the CA’s Ruling

Only private respondents appealed to the Court of Appeals. On November 13, 1989, the CA reversed the trial court. It ordered petitioners to reconvey ownership and possession to private respondents and to pay attorney’s fees of P3,000.00 plus P50.00 for each court appearance, with costs. It later denied reconsideration on May 21, 1990.

The CA’s approach, as articulated in the Court’s discussion, was that petitioners’ defense of reconveyance could not rely on the purported deed of sale. It reasoned that private respondents’ action essentially sought to declare the inexistence or nullity of the “Escritura de Venta Absoluta,” which the CA treated as imprescriptible under Article 1410. It also concluded that acquisitive prescription could not take place because petitioners’ possession was not in good faith. In that regard, it found alleged defects in the deed’s notarization requirements under Section 127 of the Land Registration Act, discrepancies in the identity of the signatory’s name in the document, the absence of the deed in the archives through a certification from the Bureau of Records Management, Antonio Tamisin’s alleged inability to execute the document on October 8, 1921 due to his service abroad in the U.S. Navy, and a conclusive finding by the Philippine National Police Academy that Antonio Tamisin’s questioned signature was not written by the same person as sample signatures.

Issues for Resolution in the Supreme Court

In reviewing the case, the Court found it unnecessary to dwell on the CA’s “lengthy disquisition” and narrowed its discussion to two essential issues: first, whether private respondents had identified the land sought to be recovered; and second, whether the action filed below was mainly for annulment of the document (and thus imprescriptible) or for reconveyance (and thus subject to prescription).

The Supreme Court’s Treatment of Land Identification

On the first issue, the Court adopted the CA’s view that the property in dispute was sufficiently identified. The Court reasoned that in resisting the action for reconveyance, petitioners claimed acquisition by the very deed of sale that described the parcels in question. Private respondents, in turn, maintained that Antonio Tamisin and Maura Tamisin did not actually sign that deed, and thus private respondents sought to recover the same parcels described therein. The Court held that it was not warranted to conclude that private respondents were unable to identify the property they sought to recover.

The Court clarified, however, that for the heirs of Maria R. Vda. de Vega, their title did not originate from the “Escritura de Venta Absoluta,” because that deed involved only Antonio Tamisin and Maura Tamisin as vendors and Sebastian Salva Cruz as vendee. Still, the Court stressed that the property sought by private respondents from Maria’s heirs was the same parcel Maria possessed and claimed. Maria had admitted in her answer that her property at the place was well-defined by metes and bounds and had been brought under the Land Registration Law. This admission, in the Court’s view, demonstrated that Maria understood that private respondents were seeking to recover the parcel she possessed.

Prescription: Nature of the Action and Governing Period

On the second issue, the Court held that the CA’s analysis based on a strained application of Article 1410 was unnecessary. The Court focused on the pleadings, emphasizing that the action filed by private respondents before the trial court was, in substance, only for reconveyance with damages based on an implied or constructive trust. The “Escritura de Venta Absoluta” was not mentioned in the complaint. Private respondents alleged instead that petitioners, in bad faith, fraud, and in violation of trust, appropriate or were appropriating for themselves the land by unlawful acts of ownership. Private respondents thus prayed for reconveyance of ownership and possession and payment of damages.

Citing Rone, et al. v. Claro, et al., 91 Phil. 250, the Court reiterated that the purpose of a suit and the law governing it, including the period of prescription, must be determined from the complaint itself—its allegations and prayer for relief—rather than from the party’s theory in argument or brief. Under this framework, an action for reconveyance based on an implied or constr

Case Syllabus (G.R. No. 93507)

Parties and Procedural Posture

Petitioners were the heirs of Maria R. Vda. de Vega and the heirs of Sebastian Salva Cruz.
Respondents were the Court of Appeals and the heirs of Antonio Tamisın, who were private respondents in the trial court.
Private respondents filed an action seeking reconveyance and damages against petitioners.
Petitioners resisted the action on the theory that the land was acquired through the “Escritura de Venta Absoluta” and that prescription barred the suit.
The Regional Trial Court rendered judgment on June 4, 1986 dismissing the complaints and ordering the payment of attorney’s fees to petitioners.
Only private respondents appealed to the Court of Appeals.
The Court of Appeals reversed on November 13, 1989, ordered reconveyance and possession in favor of private respondents, and awarded attorney’s fees plus costs.
The Court of Appeals denied reconsideration in its May 21, 1990 resolution.
Petitioners then filed a petition for review on certiorari before the Court.

Key Factual Allegations

The land at issue was located at Batong Malake, Los Banos, Laguna and was originally owned by Ignacio Revilleza, who died intestate.
Ignacio left five children—Margarita, Lorenzo, Florencio, Sinforosa, and Dominga—all surnamed Revilleza.
Margarita Revilleza had two children with Valeriano Tamisin—Antonio and Maura, both surnamed Tamisin.
Antonio Tamisin was the father of private respondents Paulino, Lorenza, Virginia, Cristeta, Emilia, Bethilda, and Dorotea, all surnamed Tamisin.
Maura Tamisin was the mother of intervenors Marciana, Lucio, Placida, Susana, Carmen, and Melencio, all surnamed Dequillo.
Lorenzo Revilleza had four children—Emilio, Macario, Marcela, and Maria R. Vda. de Vega.
Maria R. Vda. de Vega died on April 1, 1979, leaving petitioners Gloria Vega Yap, Marcos, Jr., Rogelio, Lubin, and Carlos.
Sebastian Salva Cruz was the son of Ignacio’s other daughter and died on July 24, 1974, leaving the other petitioners.
After Ignacio’s death, an Extrajudicial Partition dated March 19, 1915 was executed among Florencio, Lorenzo, Sinforosa, and Dominga, with parcels distributed to them and to Antonio Tamisin, including the parcel located at Batong Malake.
A document entitled “Escritura de Venta Absoluta” was allegedly signed on October 8, 1921 by Antonio Tamisin and Maura Tamisin, with Julio Dequillo’s conformity, and it purportedly sold one-half of the land to Sebastian Salva Cruz and the other half to Lorenzo Revilleza.
The portion allegedly sold to Sebastian had 1,611 square meters, of which 435 square meters were expropriated by the National Power Corporation in July 1941.
Since 1948, Sebastian Salva Cruz declared the remainder for taxation and paid realty taxes from 1966 to 1979.
Sebastian caused the land to be surveyed for him by Geodetic Engineer Danilo Angeles, who also prepared the plan and technical description.
When Lorenzo Revilleza died on May 15, 1928, his son Emilio Revilleza filed a registration application that led to the issuance of Original Certificate of Title RO-1100 (No. 9423) on May 20, 1929 in the names of Emilio, Macario, and Marcela Revilleza, and Maria R. Vda. de Vega.
On April 18, 1950, after the death of other co-owners, Maria R. Vda. de Vega executed an Affidavit of Adjudication, resulting in Transfer Certificate of Title No. 3911.
On August 10, 1964, the Bureau of Records Management certified that the archives failed to reveal the existence of the alleged Deed of Sale.
Antonio Tamisin filed a criminal complaint for falsification of documents against Sebastian, but it was not concluded because Antonio became sick and died on November 2, 1966.
On July 20, 1973, private respondents filed a complaint for annulment of documents, reconveyance and damages, later amended on October 14, 1974 to seek reconveyance and damages only.
The heirs of Maria R. Vda. de Vega answered on January 28, 1975, while the heirs of Sebastian answered on July 1, 1975.
On February 4, 1976, the heirs of Maura Tamisin filed a complaint-in-intervention.
Private respondents’ theory was anchored on alleged bad faith, fraud, and violation of trust, and they sought orders of reconveyance and damages.

Trial Court Issues and Reasoning

The trial court dismissed the claims for failure to establish them by preponderance of evidence.
On land identification, the trial court held that private respondents’ and intervenors’ evidence was inadequate, particularly for Maria R. Vda. de Vega, due to the weakness of sketches allegedly showing the land.
The trial court found that Geodetic Engineer Ruperto Coquia prepared sketches based on verbal information from Dorotea T. Gonzales, who was not even born at the time Antonio Tamisin’s inheritance occurred.
The trial court noted that Coquia did not conduct an actual physical survey and instead relied on documents furnished by Dorotea T. Gonzales.
The trial court observed that the documents used by Coquia were never presented and properly authenticated.
On prescription, the trial court concluded that Maria R. Vda. de Vega had been in public, peaceful, and continuous possession of the land for the relevant period and had become owner by acquisitive prescription, citing Art. 1137 of the Civil Code.
The trial court also held that the complaint and complaint-in-intervention were barred by prescription, citing Art. 1141 of the Civil Code.
The trial court found that private respondents and intervenors failed to show a document evidencing the alleged trust.
The trial court found no sufficient evidence proving that Antonio Tamisin’s signature in the “Escritura de Venta Absoluta” was a forgery.
The trial court maintained that since the deed was notarized, the presumption of regularity in the notary’s performance stood because no evidence showed otherwise.
On ownership by prescription, the trial court held that under both ordinary and extraordinary prescription, Sebastian Salva Cruz should be considered the owner.

Court of Appeals Findings

The Court of Appeals held tha