Case Summary (G.R. No. 171953)
Applicable Law
The legal framework pertinent to this case primarily includes provisions from the 1987 Philippine Constitution and the Rules of Court, particularly focusing on rules regarding property reconveyance, expropriation, and the applicable periods of prescription for claims against property rights.
Background Facts
On May 15, 1982, an extrajudicial partition was executed by heirs of the registered owners of Lot No. 4673, leading to the issuance of Transfer Certificate of Title (TCT) No. 12467. Subsequently, the expropriation of the property was initiated by the Export Processing Zone Authority (EPZA), leading to a partial decision by the RTC approving a Compromise Agreement on August 11, 1982. This agreement established that the property would be used for an export processing zone, resulting in the issuance of TCT No. 12788 to the PEZA. In 1996, the private respondents filed a complaint, challenging the legality of this transfer based on exclusion from the partition process.
CA Ruling
The Court of Appeals upheld the RTC's ruling, stating that the complaint, although labeled as one for nullity of documents, effectively served as an action for reconveyance. The CA noted that the respondents had been wronged by the fraudulent representation of the heirs, allowing a constructive trust to be applied in favor of the affected parties.
Issues Presented
The petitioner raised two primary issues for consideration:
- Whether the appellate court erred in denying that the respondents' claims against the expropriated property were already time-barred due to prescription.
- Whether the appellate court erred in rejecting the assertion that a reconveyance action was not valid against expropriated property.
Court’s Analysis on Prescription
The Supreme Court found merit in the petitioner’s argument concerning prescription. It stated that the private respondents’ claim must have been brought within two years following the extrajudicial partition. The Court emphasized that registration of the partition provided constructive notice to all interested parties. Given that the respondents did not act within the stipulated two-year timeframe, their claims against the property were deemed to have prescribed. Importantly, the Court underscored that mere registration acts as actual notice, thus barring claims of those who received said notice but chose to remain inactive.
Court's Analysis on Limitations Regarding Reconveyance
The Court also addressed the limitations related to actions for reconveyance, which generally prescribe four years from the discovery of fraud. Given the timeline, it was concluded that the respondents’ claim had exceeded this prescriptive period since they filed their lawsuit 14 years after the original registration of the title was issued. The Court clarified that while an action for reconveyance can be pursued based on constructive or implied trust, the respondents would need to establish their possession of the p
...continue readingCase Syllabus (G.R. No. 171953)
Case Overview
- This case involves a Petition for Review on Certiorari filed by the Philippine Economic Zone Authority (PEZA) against the Regional Trial Court of Lapu-Lapu City and the heirs of deceased spouses Juan Cuizon and Florentina Rapaya.
- The petition challenges the decision of the Court of Appeals which upheld the orders of the Regional Trial Court that denied PEZA's motions to dismiss a complaint filed by the respondents.
Background Facts
- The subject property is Lot No. 4673 located in Lapu-Lapu City, originally titled under Original Certificate of Title No. RO-2537.
- The property was owned by several individuals, including Florentina Rapaya and others.
- An Extrajudicial Partition was executed on May 15, 1982, by Jorgea Igot-Soro, Frisca Booc, and Felix Cuizon, claiming to be the only surviving heirs, which led to the issuance of Transfer Certificate of Title No. 12467.
- The property was later expropriated for use as an export processing zone, with the RTC approving a compromise agreement for just compensation to the new owners.
Proceedings and Initial Rulings
- On July 29, 1996, the private respondents filed a complaint for Nullity of Documents, Redemption, and Damages against PEZA and the new registered owners.
- PEZA moved to dismiss the complaint on grounds of prescription, but the Regional Trial Court denied the motion, leading