Title
Spouses Aboitiz vs. Spouses Po
Case
G.R. No. 208450
Decision Date
Jun 5, 2017
Disputed land ownership in Mandaue City involving conflicting sales, reconveyance claims, and innocent purchasers in good faith.

Case Summary (G.R. No. 121143)

Material Facts

Mariano sold two contiguous lots to son Ciriaco in 1973. Ciriaco sold both to Victoria Po in 1978. A 1989 quitclaim by Ciriaco covered only Lot 2807. In 1990, Mariano’s heirs sold Lot 2835 to Roberto, who registered title in 1993 and subdivided it, selling parcels to Ernesto and Jose. Spouses Po discovered the 1990 deeds and initiated barangay conciliation, then filed a reconveyance complaint in 1996.

Issues Presented

  1. RTC jurisdiction over reconveyance and cancellation of title
  2. Prescription of Spouses Po’s cause of action
  3. Application of estoppel and laches
  4. Binding effect of land registration findings (res judicata)
  5. Admissibility and authenticity of the 1978 Deed of Sale
  6. Indispensable parties (Mariano heirs)
  7. Status of Jose, Ernesto, and Isabel as innocent purchasers for value

RTC Jurisdiction

A complaint for reconveyance and cancellation of title involves “title to, or possession of, real property,” conferring exclusive original jurisdiction on the RTC (BP 129, Sec. 19). Such action is distinct from an annulment of judgment (reserved to the CA under BP 129, Sec. 9) because it seeks transfer of title on grounds of intrinsic fraud against the true owner rather than procedural deficiency.

Prescription

An implied or constructive trust action for reconveyance prescribes in ten years from issuance of the Torrens title (P.D. 1529, Sec. 53; CC Arts. 1144(2) & 1456). Spouses Po filed within three years of Roberto’s 1994 title issuance; their claim is timely.

Laches and Estoppel

Laches—a question of inequity, not fixed time—requires an unreasonable delay and prejudice to the respondent. Spouses Po promptly registered tax declarations, made improvements, executed a Memorandum of Agreement, and pursued barangay conciliation upon learning of the 1990 deeds. There is no undue delay or prejudice supporting laches or estoppel.

Res Judicata and Land Registration Findings

Land registration decrees are generally conclusive in rem, but an action for reconveyance is in personam and does not annul the registration decree. A true owner unaware of and unrepresented in the original proceeding may file reconveyance despite a final title. Here, Spouses Po were neither parties nor given an opportunity to litigate their claim in LRC Case No. N-208. The RTC’s finding of a trust in Ciriaco’s favor does not bar subsequent proof of fraud.

Authenticity of the 1978 Deed of Sale

The Deed of Absolute Sale between Ciriaco and Spouses Po was duly notarized and attracts a presumption of regularity (Rules of Court, Rule 132, Sec. 30). Certifications of missing notarial records do not prove non-existence or fraud. Petitioners failed to present clear and convincing evidence to overcome the presumption; the deed remains admissible and authentic.

Indispensable Parties

Only persons whose rights could be prejudiced by the court’s decree—namely, the registered owners and downstream purchasers—are indispensable. The Mariano heirs, as alleged sellers whose interests were fully alienated by later deeds, are not indispensable. They are, at most, necessary parties or material witnesses, but their absence

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