Case Summary (G.R. No. 108547)
Petitioner and Respondent
Petitioners: Felicidad Vda. de Cabrera, Marykane Cabrera, and Felicidad Teokemian
Respondent: Virgilia Orais de Felicio (represented by attorney-in-fact Ernesto M. Orais) and the Court of Appeals
Key Dates
– January 16, 1950: Deed of Sale by Daniel and Albertana Teokemian to Andres Orais (Felicidad’s name printed but unsigned)
– January 26, 1950: Survey of Lot No. 2239 in Virgilia’s name
– June 24, 1957: Free Patent and Torrens Title issued to Virgilia
– July 27, 1972: Albertana Teokemian’s Deed of Absolute Sale to Elano and Felicidad Cabrera of a defined portion
– February 11, 1988: Virgilia’s suit for quieting of title and damages filed
– April 27, 1989: RTC judgment favoring petitioners on laches
– January 7, 1993: Court of Appeals decision reversing RTC
– February 3, 1997: Supreme Court decision
Applicable Law
1987 Constitution; Civil Code provisions on implied trust (Art. 1456), co-ownership (Arts. 493–494); principles on Torrens indefeasibility, prescription, and equitable laches.
Factual Background
Three Teokemian siblings inherited unregistered land. Daniel and Albertana sold the entire parcel in 1950 without Felicidad’s signature. Despite this flaw, plaintiff’s predecessor secured Torrens registration. In 1972 Albertana purported to sell an eastern portion (55,510 sqm) to the Cabreras, who occupied the western portion. Plaintiff only asserted her registered title in 1988.
Procedural History
RTC (1989): Dismissed plaintiff’s quieting action, applying laches to bar recovery by Virgilia, and granted reconveyance to petitioners for the precisely occupied portion.
CA (1993): Found the 1972 sale void for lack of co-owner consent but held petitioners’ reconveyance action barred by prescription; rejected laches as only 14 years elapsed. Reversed RTC.
SC (1997): Granted petitioners’ certiorari, reinstating RTC.
Issue
Whether petitioners’ implied-trust reconveyance defense was barred by prescription or laches, and whether plaintiff’s quieting-action is maintainable despite Torrens indefeasibility principles.
Court of Appeals’ Conclusion
- 1972 Deed was void as Albertana lacked authority over Felicidad’s undivided one-third, so petitioners held no title.
- Petitioners’ reconveyance remedy prescribed after ten years from registration.
- Plaintiff’s suit was timely (14 years since knowledge), and laches did not apply due to shorter delay.
Supreme Court’s Analysis
– Torrens indefeasibility does not protect a title obtained by fraud or notice of defect; plaintiff held Felicidad’s share in implied trust (Art. 1456).
– Petitioners, in actual possession, may defend via reconveyance indefinitely unless clear repudiation ousted
Case Syllabus (G.R. No. 108547)
Procedural History
- Petition for Review on Certiorari filed before the Supreme Court assails the Court of Appeals Decision dated January 7, 1993 in CA-G.R. No. 22407-CV.
- The Court of Appeals reversed the RTC, Branch 7, Baganga, Davao Oriental’s April 27, 1989 Decision in Civil Case No. 379 (Quieting of Title to Real Property, Damages with Preliminary Injunction).
- The RTC had ordered reconveyance of the disputed portion and awarded costs, litigation expenses, and attorney’s fees to the defendants.
- The Supreme Court granted the petition, set aside the appellate ruling, and reinstated the trial court’s decision in toto.
Facts
- January 16, 1950: Daniel and Albertana Teokemian executed a Deed of Sale to Andres Orais over 7.3720 ha of unregistered land at Abejod, Cateel, Davao Oriental. Felicidad Teokemian’s name was printed but not signed.
- January 26, 1950: Surveyed as Lot No. 2239 (11.1000 ha) in the name of Virgilia Orais (Andres’s daughter).
- June 24, 1957: Free Patent No. V-79089 and Certificate of Title No. P-10908 issued to Virgilia Orais.
- July 27, 1972: Albertana Teokemian purportedly sold to Elano Cabrera (and wife Felicidad Cabrera) a half portion (55,510 sqm) of Lot 2239, claiming it was Felicidad Teokemian’s one-third share.
- 1965 cadastral court decision allegedly adjudicated the whole lot to Albertana, justifying the 1972 sale.
- Cabreras took possession of the western portion of Lot 2239 and cultivated it.
- 1974 & 1978: Rodolfo and Jimmy Orais confronted the Cabreras over alleged encroachment; no formal action followed.
- February 11, 1988: Virgilia filed Civil Case No. 379 for quieting of title, damages, and preliminary injunction, amended June 22, 1988 to include Felicidad Teokemian as co-defendant.
Trial Court Ruling (RTC, April 27, 1989)
- Held that plaintiff must reconvey to defendant Felicidad Cabrera the portion of Lot 2239 actually possessed by defendants, as shown in the ocular survey.
- Ordered plaintiff to reimburse defendants for litigation expenses (₱7,000) and attorney’s fees, and to pay costs.
- Found plaintiff’s claim barred b