Case Summary (G.R. No. 18500)
Facts of the Case
The dispute originated in 1977 before the Court of First Instance of Iloilo, which ruled in favor of the respondents. This judgment was upheld on appeal by the Intermediate Court of Appeals. The crux of the issue pertains to the Transfer Certificate of Title No. T-14243 issued on June 8, 1953, by the Register of Deeds of Iloilo, which recorded the property in the name of Adalia Penaflorida, along with certain encumbrances signaling potential claims from the heirs of Segundo Lustria, who had died in 1931.
Sale and Title Transfer
On August 25, 1970, Adalia sold the entire property to the petitioners. Following this sale, they were issued Transfer Certificate of Title No. T-63055, which maintained the recorded encumbrances from TCT No. T-14243. In 1972, the petitioners executed an affidavit titled “Cancellation of Two Years Claim,” effectively cancelling the encumbrance regarding Segundo Lustria’s heirs, which was duly registered. This cancellation prompted the heirs, who claimed entitlement to half of the property, to initiate a legal action for reconveyance and damages in March 1977.
Trial Court’s Decision
The Trial Court determined that Adalia only possessed a half-share of the property at the time of the sale to the petitioners and ordered the transfer of ownership back to the Lustrias. Additionally, it awarded them moral and exemplary damages, as well as attorney's fees, under the premise that petitioners had adversely appropriated the entire property.
Appeals and Appellate Court Ruling
The Intermediate Appellate Court affirmed the Trial Court’s ruling, suggesting that the cancelation of the encumbrance only allowed the Lustrias to claim an implied trust on the property, which would be actionable within ten years per Article 1456 of the New Civil Code. The court concluded that the Petitioners set up an adverse title only upon cancelling the encumbrance in 1972; thus, the period for claims had not yet lapsed.
Reversal of the Appellate Court Decision
Upon review, it was determined that the Appellate Court misinterpreted key aspects of the case. Specifically, it was erroneous for the court to assert that the adverse claim only commenced upon the cancellation of the annotation in 1972, rather than recognizing that it started on June 8, 1953—when the title was issued in Adalia’s name. The heirs of Segundo Lustria were considered to have constructive notice of the title and the potential claims stemming from it from that date.
Constructive Notice and Prescription
The ruling reinforced that the rights of the Lustrias were extinguished beyond the two-year claim period set forth under S
...continue readingCase Syllabus (G.R. No. 18500)
Case Overview
- The case revolves around a dispute concerning the ownership of a one-half share in Lot No. 6026 of the cadastral survey of Pototan, Iloilo, which encompasses an area of approximately 3,145 square meters.
- Petitioners in the case are Maria Penales and Consorcia Penales, accompanied by her husband Felipe Lustria, while the respondents are Salvacion Lustria, Alvaro Porras, Madonna Lustria, Eladio Dasmarinas, and Segundo Lustria Jr.
- The litigation began in 1977 in the Court of First Instance of Iloilo, which ruled in favor of the private respondents. This decision was later affirmed by the Intermediate Court of Appeals, prompting the current petition for review.
Historical Context and Initial Proceedings
- The pivotal date in the case is June 8, 1953, when the Register of Deeds of Iloilo issued Transfer Certificate of Title No. T-14243 in the name of Adalia Penaflorida.
- The title indicated that the property was registered in fee simple to Adalia but was subject to claims for one-half of the property by the heirs of Segundo Lustria, for a period of two years from the date of registration.
- The respondents, the Lustrias, are the children of Segundo Lustria, who died in 1931.
- On August 25, 1970, Adalia sold the entire property to the petitioners, who w