Case Summary (G.R. No. 185757)
Background of the Property
The contested property was originally owned by Leoncio Bajao, who acquired Lot No. 532 through Free Patent No. 400087 issued on May 28, 1968. The petitioners acquired portions of this lot in two separate transactions, with the first sale occurring on May 24, 1969 (200 square meters for P1,000) and the second on June 18, 1970 (280 square meters for P1,400). Both transactions were memorialized through Deeds of Absolute Sale, which included a promise from the Bajao spouses to segregate the purchased portions and provide a separate title, a promise that remained unfulfilled.
Legal Proceedings Initiated by Petitioners
Due to the unfulfilled promise, Lydia S. de Guzman filed an Affidavit of Adverse Claim on April 21, 1980, which was annotated on the title for Lot No. 532. Subsequently, the petitioners initiated the process of segregating their acquired property, which led to the issuance of Lot 2-A. After the death of Leoncio Bajao on February 1, 1972, respondent Lamberto Bajao and his mother executed an Extrajudicial Settlement which subdivided Lot No. 532 among the heirs, assigning Lot 532-C (the land in contention) to Lamberto. In 1980, Lamberto canceled the petitioners' adverse claim and secured Transfer Certificate of Title (TCT) No. T-7133.
Complaint for Reconveyance
On January 21, 2000, the petitioners filed a Complaint for Reconveyance with a Writ of Preliminary Mandatory Injunction and Damages, asserting that they were innocent purchasers of the property and claiming the respondent acted in bad faith. The respondent countered that the petitioners' claim was time-barred and argued that there was no fraud in the registration of TCT No. T-7133 as a result of the Extrajudicial Settlement.
Ruling of the Trial Court
On October 22, 2004, the Regional Trial Court ruled in favor of the petitioners, reinforcing the validity of the Deeds of Absolute Sale, stressing that such deeds convey ownership rights regardless of registration, and found the respondent acted in bad faith by ignoring the petitioners' claim and the adverse annotation. The trial court ordered the reconveyance of the property to the petitioners.
Decision of the Court of Appeals
Upon appeal, the Court of Appeals reversed the trial court's decision. Citing the creation of an implied trust under Article 1456 of the Civil Code, the CA ruled that the action for reconveyance based on that trust prescribes after 10 years. The court determined that the petitioners’ action filed in January 2000 was time-barred since more than 10 years had elapsed since the registration of TCT No. T-7133 in 1981. The CA also questioned the sufficiency of evidence of the petitioners’ possession of the property and ruled them guilty of laches for not asserting their rights sooner.
Petition for Review and the Supreme Court's Ruling
The petitioners contested the CA's ruling before the Supreme Court, raising issues of prescription and possession, particularly disputing the CA's finding of their lack of actual possession. The Supreme Court affirmed the CA’s decision, emphasizing the prohibition against the alienation of lands acquired via a free patent within five years
...continue readingCase Syllabus (G.R. No. 185757)
Case Citation
- G.R. No. 185757
- Date Decided: March 02, 2016
- Jurisprudence Reference: 782 Phil. 71
Parties Involved
- Petitioners: Spouses Virgilio de Guzman, Jr. (substituted by his wife, Lydia S. de Guzman, and children: Ruel S. de Guzman, et al.)
- Respondents: Court of Appeals, Mindanao Station; Lamberto Bajao (heir of Spouses Leoncio Bajao and Anastacia Z. Bajao)
Procedural History
- Petitioners filed a Petition for Review on Certiorari against the Decision and Resolution of the Court of Appeals dated August 27, 2008, and November 19, 2008, respectively.
- These appellate decisions reversed the Regional Trial Court's ruling from October 22, 2004, which had favored the petitioners by granting their action for reconveyance and damages.
Facts of the Case
- The property in question is a 480-square meter lot part of Lot No. 532 located in North Poblacion, Medina, Misamis Oriental.
- Lot No. 532, with a total area of 25,178 square meters, was acquired by Leoncio Bajao through Free Patent No. 400087 on May 28, 1968.
- Petitioners purchased portions of Lot No. 532 in two transactions:
- 200 square meters for P1,000 on May 24, 1969.
- 280 square meters for P1,400 on June 18, 1970.
- Both transactions were documented through Deeds of Absolute Sale, where the Spouses Bajao promised to segregate the property and issue a separate title.
- An Affidavit of Adverse Claim was executed by Lydia S. de Guzman on April 21, 1980, which was annotated on the title covering Lot No. 532.
- Petitioners attempted to segregate the property through a survey on May 29, 1980, result