Case Summary (G.R. No. L-25375)
Procedural Background
Anicia T. Reyes filed a complaint in the Court of First Instance of Bulacan on May 19, 1965, seeking to recover ownership and possession of a parcel of land from the appellees or to compel its reconveyance, along with damages. The defendants filed a motion to dismiss the complaint on June 22, 1965, claiming that Reyes’ cause of action was barred by the statute of limitations. The court granted this motion on July 12, 1965, leading Reyes to appeal the decision.
Issue for Resolution
The primary issue in this appeal is whether Reyes’ cause of action had indeed prescribed by the time she initiated her complaint on May 19, 1965, based on the facts alleged in her complaint.
Background Facts Alleged
Reyes alleged that on December 26, 1946, the defendants, acting in bad faith, purchased the same parcel of land previously contracted to her in 1943 by Antonio de Pano. She claimed that the defendants unlawfully declared the land in their names beginning in 1948 and canceled her tax declaration. The defendants continued to occupy and declare the disputed land despite Reyes’ protests, asserting ownership and claiming a Torrens title established by their registration proceedings that were resolved in their favor in 1947.
Prescription of Action
The court pinpointed that Reyes learned of the alleged sale by De Pano to the defendants in 1947. The summary of the facts indicated that Reyes failed to file her action for approximately 18 years following the issuance of the Original Certificate of Title in favor of the defendants. This significant delay led the court to conclude that Reyes' action—whether viewed as an action for recovery of possession (ac acción reinvindicatoria) or a personal action for reconveyance—was indeed barred by the statute of limitations.
Fraud and Annulment Claims
Reyes argued that she might annul the deed based on alleged fraud. However, the court found that the facts she provided did not adequately establish a claim for extrinsic fraud sufficient to annul the registration proceedings or the deed of sale executed by De Pano. Consequently, the court dismissed her claims.
Rulin
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Case Overview
- The case involves Anicia T. Reyes (plaintiff-appellant) appealing an order from the Court of First Instance of Bulacan dismissing her complaint against Gregorio Apostol and Adelaida Carpio Apostol (defendants-appellees).
- The dismissal was based on the grounds that the cause of action was barred by the statute of limitations.
Factual Background
- On May 19, 1965, Anicia T. Reyes filed a complaint seeking ownership and possession of a parcel of land located in barrio San Sebastian, Hagonoy, Bulacan, or alternatively for its reconveyance and damages.
- The defendants filed a motion to dismiss on June 22, 1965, claiming the statute of limitations barred the action.
Legal Issue
- The primary issue before the court was whether the cause of action alleged by the appellant had already prescribed when the action was commenced on May 19, 1965.
Allegations in the Complaint
- Bad Faith and Knowledge of Prior Contract (Paragraph VII):
- The defendants allegedly conspired with Antonio de Pano to repurchase a parcel of land that Reyes had a prior contract for since 1943.
- Declaration of Land and Double Cancellation (Paragraph VIII):
- The defendants declared the land under their name on April 25, 1947, while unlawfully cancelling Reyes' prior tax declar