Case Summary (G.R. No. 46278)
Factual Background
On August 21, 1951, the plaintiffs filed a lawsuit in the Court of First Instance of Camarines Sur to recover a land parcel of approximately 41 hectares. They sought the cancellation of Transfer Certificate of Title No. 577, which they claimed was fraudulently obtained by the defendant. The defendant filed a motion to dismiss on December 21, 1951, citing the grounds of lack of cause of action and prescription. Initially, the court denied the dismissal motion, but later, upon the defendant's second motion emphasizing prescription, the court dismissed the case based on that premise.
Historical Title and Fraud Allegations
The plaintiffs alleged that the homestead application was applied for during the marriage of Felix and Ciriaca. Despite Ciriaca's death prior to the issuance of the patent, Felix continued the application, and the patent was granted along with Original Certificate of Title No. 1056 in the name of "heirs of Felix Sevilla." After Felix married the defendant, he died, and the defendant allegedly misled authorities to cancel the original title and obtain a new one in her name, thus committing fraud.
Court’s Reasoning Regarding Prescription
In dismissing the case on the basis of prescription, the court determined that the plaintiffs had constructive notice of the fraud, given that the certificate of title issued in favor of the defendant was a public record. The court pointed out that the plaintiffs had not specified when they discovered the alleged fraud, thus implying they should have acted sooner since the fraudulent activities and the issuance of Transfer Certificate No. 577 took place in 1936.
Nature of the Action and Constructive Trust
However, the plaintiffs' action was characterized not merely as a recovery of a real property but as one compelling a trustee to convey property held in trust for the plaintiffs' benefit. The court found that prescription does not apply to actions aimed at enforcing a trust. The ruling establishes a legal principle whereby a beneficiary can recover property from one who holds the title wrongfully, regardless of how much time has elapsed since fraud occurred.
Legal Principles Underlying the Decision
The decision aligns with established legal tenets that dictate that:
- Prescription does not run against the true owner in cases of constructive trusts.
- A denier of trust cannot benefit from the lapse of time during
Case Syllabus (G.R. No. 46278)
Case Background
- The case was initiated by the plaintiffs, Candida Sevilla and others, on August 21, 1951, in the Court of First Instance of Camarines Sur.
- The plaintiffs sought recovery of a parcel of land measuring approximately 41 hectares, 14 ares, and 92 centares.
- They also requested the cancellation of Transfer Certificate of Title No. 577, claiming it was obtained by the defendant, Concordia de los Angeles, through fraudulent means.
Procedural History
- On December 21, 1951, the defendant filed an answer presenting several affirmative defenses.
- A motion to dismiss was filed by the defendant on August 20, 1952, claiming that the complaint lacked a cause of action and was barred by prescription.
- The court initially denied the first motion to dismiss, but later reconsidered its ruling and dismissed the case on October 20, 1953, based on the defense of prescription.
Facts of the Case
- The plaintiffs are the legitimate children of Felix Sevilla and Ciriaca Ramos.
- Felix and Ciriaca applied for a homestead in Siruma, Camarines Sur; however, Ciriaca passed away before the issuance of the patent.
- Despite her death, Felix continued with the homestead application, and on April 27, 1934, a patent was granted, leading to the issuance of Original Certificate of Title No. 1056 in the name of the "heirs of Felix Sevilla."
- After Felix married the defendant, he d