Case Summary (G.R. No. 178609)
Background of the Case
The case arises from a dispute over a residential lot owned by Manuel and Romulo Ney, who are the registered owners of the property covered by Transfer Certificate of Title (TCT) No. 122489. The property contains a three-door apartment, one unit of which was occupied by the respondents, Celso and Mina Quijano. The respondents filed a suit for reconveyance, partition, and damages against the petitioners, claiming co-ownership since they contributed to the purchase price but were omitted from the title.
Proceedings in the Regional Trial Court
The respondents asserted that Celso Quijano's name was inadvertently left out from the deed of sale during the property transaction, preventing the registration of his ownership. They sought to rectify this by requesting the lot's partition, a plea that the petitioners refused. The trial court dismissed the respondents’ complaint, stating that they held the property only through the petitioners’ tolerance and that any potential claim had already been barred by prescription and/or laches.
Court of Appeals Decision
Upon appeal to the Court of Appeals, the decision of the Regional Trial Court was reversed. The appellate court determined that the respondents had presented sufficient evidence to prove their claim of co-ownership and recharacterized their action as one for quieting of title, which is imprescriptible. It ordered that the property be partitioned and that the title be reconveyed to the respondents.
Arguments from Petitioners
The petitioners challenged the Court of Appeals' decision, arguing that the lower court had improperly characterized the respondents' action as one for quieting of title rather than strictly for partition and reconveyance. They maintained that the matter of co-ownership was not substantiated and claimed that the appellate court's ruling introduced an entirely new legal issue which was not pleaded by the respondents.
Rebuttal and Analysis
The Supreme Court reviewed the allegations in the respondents' complaint, affirming that they had clearly sought not only to partition the property but also to recover their rightful share through reconveyance. The ruling reaffirmed that an action for reconveyance is distinct yet related to an action for quieting of title, as it seeks to transfer property wrongfully registered in another's name back to its rightful owner. The Supreme Court upheld that the action for reconveyance does not prescribe if the claimant remains in possession of the property.
Ownership Documentation and Evidence
The Deed of Reconveyance executed
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Case Background
- The case centers around a dispute regarding ownership of a residential lot located at 1648 Main Street, Paco, Manila, covering an area of 120 square meters, under Transfer Certificate of Title (TCT) No. 122489.
- Petitioners, Manuel P. Ney and Romulo P. Ney, are the registered owners of the property, on which a three-door apartment was constructed for their use and that of their sister, Mina N. Quijano, and her husband, Celso Quijano (respondents).
- On October 8, 1999, respondents filed a suit for reconveyance, partition, and damages against the petitioners, claiming co-ownership of the property based on their contribution to the purchase price and alleging that Celso's name was omitted from the deed of sale.
Proceedings in the Regional Trial Court (RTC)
- Respondents asserted that they requested the segregation of their portion of the property, which petitioners refused.
- The RTC dismissed the complaint, upholding petitioners' denial of co-ownership and asserting that respondents' possession was based on mere tolerance.
- The RTC also ruled that respondents' cause of action was barred by prescription and laches, thus granting petitioners