Case Summary (G.R. No. 254194)
Background and Factual Summary
The controversy commenced when, on May 31, 1991, Rosita and her deceased husband Jesus were claimed to have donated the subject property to Lazaro. Following this donation, TCT No. 141543 was issued in Lazaro's name, thereby canceling TCT No. 104125, which had registered the property to the Zamoras. It is significant to note that Jesus Zamora passed away on the same day the deed was notarized. In March 2015, Rosita filed an Affidavit of Adverse Claim alleging forgery of the signatures on the Deed of Donation, consequently leading to the annotation of her claim on TCT No. 141543.
Subsequently, Lazaro transferred the property to her children, the Bagatsings, who registered it under a new title. This prompted the Bagatsings to seek a legal petition for cancellation of Rosita's adverse claim. During these events, Rosita highlighted a loan taken by the Zamoras, secured against the property, and Lazaro’s involvement in its redemption, which culminated in her unintended relinquishment of ownership.
Ruling of the Regional Trial Court
The Regional Trial Court (RTC) of Pasay City ruled against the Bagatsings, finding the Deed of Donation to be a forgery. The RTC's decision, issued on May 24, 2018, maintained Rosita's adverse claim and dismissed the Bagatsings’ petition for cancellation of the adverse claim, emphasizing the weight of evidence supporting Rosita’s assertions of forgery.
Ruling of the Court of Appeals
The Court of Appeals (CA) reversed the RTC's ruling, suggesting the case was barred by the statute of limitations and laches. It asserted that Rosita's right to contest the validity of the transfer had prescribed since she allegedly did not file an action for reconveyance within the 10-year period following the registration of Lazaro as the property's owner in 1998. Despite acknowledging the forgery of the signatures on the Deed of Donation, the CA still ruled in favor of the Bagatsings in its decision dated November 28, 2019.
Issues Presented for Resolution
At the core of the case were two primary legal questions:
- Whether the CA erred in addressing the statute of limitations concerning the action for reconveyance and its relevance to the appealed land registration case.
- Whether the CA incorrectly ruled that the action for reconveyance based on a forged instrument had prescribed.
The Court's Ruling
The Supreme Court found merit in Rosita's motion to overturn the CA's decision, specifically acknowledging that while the CA rightly discussed prescription as raised in the Bagatsings’ briefs, it erred in applying this principle to the petition for cancellation of the adverse claim. The original action involved the cancellation of an adverse claim rather than an action for reconveyance, which are fundamentally different mechanisms under property law.
In assessing the petition, the Court stressed that an action for reconveyance relates to a rightful owner enforcing title against a wrongfully registered title. In contrast, an adverse claim serves to notify potential buyers of ownership disputes. Therefore, the CA's ruling based on the prescriptive period was inappropriate given the nature of Rosita's filing, which stemmed from assertions of forgery—an aspect that affects the underlying validity of
...continue readingCase Syllabus (G.R. No. 254194)
Case Background and Parties Involved
- The case involves a dispute over a 439-square-meter parcel of land located in Pasay City.
- The land was originally registered under Transfer Certificate of Title (TCT) No. 104125 in the names of spouses Rosita and Jesus Zamora.
- Respondents Ramon L. Bagatsing, Jr., Rosarity L. Bagatsing, Reynaldo L. Bagatsing, and Marilyn Bagatsing-Topacio (collectively Bagatsings) claim ownership through a purported donation.
Facts of the Case
- Spouses Zamora allegedly executed a notarized Deed of Donation dated May 31, 1991, donating the subject property to Zenaida Lazaro (Rosita's aunt).
- Subsequent to the alleged donation, TCT No. 141543 was issued in Lazaro's name, cancelling the original TCT No. 104125.
- Jesus Zamora died of prostate cancer early morning on the same day the deed was signed.
- About 24 years later, in 2015, Rosita filed an Affidavit of Adverse Claim on the grounds that the signatures on the Deed of Donation were forged.
- Lazaro later executed a Deed of Sale transferring the property to the Bagatsings, who registered it under TCT No. 003-2016000407 with an annotation of adverse claim.
- The annotation prompted the Bagatsings to petition for cancellation of the adverse claim annotation.
Trial Court (RTC) Ruling
- The RTC dismissed the Bagatsings' petition to cancel the annotation of adverse claim.
- The RTC found that the Deed of Donation was forged, supporting Rosita's adverse claim.
- The RTC emphasized the credibility and weight of Rosita's evidence over that of the Bagatsings.
Arguments on Appeal
- Bagatsings argued that RTC erred in valuing Rosita's self-serving testimonies and claimed Rosita's claim was barred by the statute of limitations due to the long delay in asserting ownership.
- Rosita countered that the RTC was correct in its findings and that prescription and laches did not apply.
Court of Appeals (CA) Ruling
- The CA reversed the RTC decision,