Case Summary (G.R. No. L-39047)
Factual Background and Proceedings
The petitioners filed an action for reconveyance with damages against the respondents, who instead of answering, filed a motion to dismiss based on lack of cause of action and the statute of limitations. The trial court denied the motion, eventually declaring the respondents in default for failing to file an answer. The petitioners presented their evidence, establishing they were deprived of land and its produce for over twenty years, having no knowledge of the sale which took place on May 8, 1951.
Findings of the Trial Court
The trial court found sufficient evidence demonstrating that the petitioners did not consent to the sale of the land, and that their brother Martin acted fraudulently in selling the entire property. The court noted that an action based on fraud must be filed within four years from its discovery, as stipulated in the New Civil Code.
Ruling on Statute of Limitations
However, the trial court determined that the petitioners had knowledge of the deed of sale before filing their complaint on May 31, 1973, emphasizing the lapse of more than twenty years since the execution of the deed. Consequently, the court ruled that the petition had long been barred by the statute of limitations.
Petitioner's Contentions
Dissatisfied with the trial court's ruling, the petitioners raised issues on appeal, arguing that the trial court erred in dismissing their case on the ground of prescription after previously denying a motion to dismiss for the same reason. They contended that the trial court's conclusion regarding their awareness of the sale was speculative, asserting that they only learned of the sale in 1973.
Court's Analysis of Prescription and Default
The appellate court found that the trial court's initial denial of the motion to dismiss did not preclude it from later addressing the statute of limitations issue, as that matter was not adjudicated on its merits. The court highlighted that it was implausible the petitioners were unaware of the sale, given their long-standing relationship with the respondents and the protracted deprivation from the property's benefits.
Legal Precedents on Prescription
The appellate court referenced established case law indicating that the obligation to file an action on fraud begins at the discovery of the fraudulent act, which was determined, at the latest, to have occurred with the issuance of the original certificates of title to the respondents in 1958. Thus, any action for reconveyance ought to have been filed by 1963, significantly prior to the 1973 complaint.
On Default Judgme
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Case Overview
- Court: Supreme Court of the Philippines
- Date of Decision: April 30, 1985
- Case Reference: G.R. No. L-39047
- Division: First Division
- Parties Involved:
- Petitioners: Alberto Pascua, Crispina Pascua, Sotera Pascua, Eduardo Molina
- Respondents: Hon. Alfredo C. Florendo, Clemente Castro, Juliana O. Castro
Background of the Case
- This case involves a petition for review on certiorari, wherein the petitioners sought to annul a decision made by the Court of First Instance of Cagayan.
- The trial court had dismissed the petitioners' action for reconveyance with damages, ruling that the action was barred by the statute of limitations.
Factual Background
- Petitioners initiated a complaint for reconveyance with damages against private respondents, spouses Clemente and Juliana Castro.
- The respondents did not file an answer but instead moved to dismiss the complaint, claiming no cause of action and that the action was barred by prescription.
- The trial court denied the motion to dismiss, subsequently declaring the respondents in default for failing to answer.
- Petitioners then presented their evidence ex-parte.
Findings of the Trial Court
- Evidence presented indicated:
- The relationship