G.R. No.
163130 September 7, 2007 ISSUE:
SAN ROQUE REALTY AND DEVELOPMENT CORPORATION, petitioner, Whether or not SRRDC acquired the land.
vs.
REPUBLIC OF THE PHILIPPINES (through the Armed Forces of the RULING:
Philippines), respondent.
The Court ruled that SRRDC is the owner of the land.
The trial court correctly held that title registered under the Torrens system is
FACTS: notice to the world. Every person dealing with registered land may safely rely on
the correctness of its certificate of title and the law will not oblige him to go
In 1940s, several parcels of land were the subject of an expropriation proceeding beyond what appears on the face thereof to determine the condition of the
initiated by the then Commonwealth of the Philippines. The CFI ordered the property.
government to deposit P9,500 for the expropriation which was complied with but
the subject parcel of land was not transferred to the government. The conveyance history of the subject properties is clearly shown on the titles of
SRRDC’s predecessors-in-interest. Absent a showing that SRRDC had any
Eventually, the land was subdivided and new titles were issued by the Register of participation, voluntary or otherwise, in the transfers by the original owners of
Deeds which was acquired by SRRDC. The government filed a case alleging that Lot No. 933, prior to its eventual acquisition of the same, we affirm that SRRDC
it is the owner of the subject parcels of land by virtue of the 1938 Decision in the is a buyer in good faith and an innocent purchaser for value.
expropriation case, thus, the new titles are null and void. SRRDC averred that it
was a buyer in good faith. It also averred that the government never secured a An innocent purchaser for value is one who, relying on the certificate of title,
title in its name, never actually took possession of subject parcels of land. bought the property from the registered owner, without notice that some other
person has a right to, or interest in, such property, and pays a full and fair price
CFI Decision for the same, at the time of such purchase, or before he has notice of the claim or
interest of some other person in the property.
The RTC rendered a decision dismissing the Republic's complaint on the
grounds that the SRRDC’s ownership is borne out by the original owner's title Section 32 of Presidential Decree No. 1529 that the decree of registration shall
and the subsequent transferees’ respective titles all of which bore no annotation not be reopened or revised by reason of absence, minority, or other disability of
of the fact of expropriation and did not indicate the Republic's favorable lien. It any person adversely affected thereby, nor by any proceeding in any court for
also found that there was no valid expropriation since the records are bereft of a reversing judgments, subject, however, to the right of any person, including the
showing that consideration was paid for the subject properties. government and the branches thereof, deprived of land or of any estate or
interest therein by such adjudication or confirmation of title obtained by actual
CA Decision fraud, to file in the proper Court of First Instance a petition for reopening and
review of the decree of registration not later than one year from and after the date
The CA reversed the RTC Decision on the finding that the appeal from the CFI
of the entry of such decree of registration, but in no case shall such petition be
Decision in the expropriation case was never perfected by the original owners of
entertained by the court where an innocent purchaser for value has acquired the
the subject properties and thus, the expropriation of Lot No. 933 became final
land or an interest therein, whose rights may be prejudiced. Whenever the
and binding on the original owners, and SRRDC, which merely stepped into the
phrase "innocent purchaser for value" or an equivalent phrase occurs in this
latter's shoes, is similarly bound. The CA further held that laches and estoppel
Decree, it shall be deemed to include an innocent lessee, mortgagee, or other
cannot work against the Republic despite its failure from 1940 to register the lot
encumbrancer for value.
in its name, or to record the decree of expropriation on the title.
In the instant case, the Republic’s adverse claim of ownership over the subject
properties may have given SRRDC’s predecessors-in-interest, the sellers, voidable
title to the subject properties. However, we stress that prior to SRRDC’s
acquisition of the subject properties, Lot No. 933 had already been subdivided
and covered by separate titles of the subsequent transferees. These titles,
including the titles to the subject properties, had not been voided at the time of
the sale to SRRDC in 1994. As such, SRRDC acquired good title to the subject
properties, having purchased them in good faith, for value, and without notice of
the seller’s defect of title, if any.
WHEREFORE, premises considered, the petition is GRANTED. The decision of
the Regional Trial Court is REINSTATED.
G.R. No. 71110 November 22, 1988 RULING:
PAZ VILLAGONZALO, ESTELA VILLAGONZALO, AIDA VILLAGONZALO, The Court ruled that the CA is correct and the action must be denied.
HERMINIA VILLAGONZALO, GWENDOLYN VILLAGONZALO, JENSINE
VILLAGONZALO and LEONILA VILLAGONZALO, petitioners, It is now well settled that an action for reconveyance of real property to enforce
vs. an implied trust shall prescribe after ten years, since it is an action based upon
INTERMEDIATE APPELLATE COURT and CECILIA A. an obligation created by law, and there can be no doubt as to its prescriptibility.
VILLAGONZALO, respondents.
It is established that said period of ten years is counted from the date adverse
title to the property is asserted by the possessor thereof. In the case at bar, that
assertion of adverse title, which consequently was a repudiation of the implied
FACTS: trust for the purpose of the statute of limitations, took place when the title was
issued in the name of Cecilia on July 18, 1962.
Juan C. Villagonzalo, the predecessor-in-interest of the parties, purchased a lot
from Roman Matuguina. It was made to appear however that the sale was in There is also evidence of record that as far back as 1961, private respondent
the name of his daughter, Cecilia Villagonzalo, who was single, since he borrowed refused to give any share in the produce of the land to petitioners; that in 1963
from her the sum of P500.00 to complete the full payment of the price of the lot. she mortgaged the property in her own name; and that in 1969, she leased the
Consequently, the title was issued in the name of Cecilia A. Villagonzalo as the same to one Ramon Valera, without the petitioners taking preventive or
registered owner. retaliatory legal action.
Paz Villagonzalo et al filed a case for reconveyance against the Cecilia The rule in this jurisdiction is that an action to enforce an implied trust may be
Villagonzalo. barred not only by prescription but also by laches, in which case repudiation is
not even required. Whether the trust is resulting or constructive, its
The RTC ruled in favor of Paz Villagonzalo, when appealed, the CA reversed the enforcement may be barred by laches. Petitioners were, therefore, correctly
RTC ruling and dismissed the complaint. faulted for their unjustified inaction.
The CA ratiocinated that when Cecilia obtained the title in her name she thereby WHEREFORE, the judgment of the Court of Appeals is hereby AFFIRMED.
excluded herein petitioners from the estate of their deceased predecessor-in-
interest and, consequently, she set up a title to the land adverse to them. The
registration of the deed of sale with the Register of Deeds, so it opined, was
constructive notice to the whole world of defendant's adverse claim to the
property, thereby repudiating any fiduciary or trust relationship involved. It
anchored its conclusion on doctrinal holdings that an action for reconveyance
based on an implied or constructive trust prescribes in ten years counted from
the date when adverse title is asserted by the possessor of the property and that
Paz Villagonzalo et al are barred by laches because of their because of the neglect
and inaction.
Paz Villagonzalo et al raised their case to the Supreme Court.
ISSUE:
Whether or not the action for reconveyance will prosper.
G.R. No. 168800 April 16, 2009 already become final and incontrovertible but within four years from the
discovery of the fraud, or not later than 10 years in the case of an implied
NEW REGENT SOURCES, INC., Petitioner, trust. NRSI failed to show the presence of these requisites.
vs.
TEOFILO VICTOR TANJUATCO, JR., and VICENTE CUEVAS, Respondents. It is undisputed that Tanjuatco derived his title to the lands from Original
Certificate of Title (OCT) No. 245 registered in the name of the Republic of the
Philippines.
FACTS: NRSI failed to substantiate its claim of entitlement to ownership of the lands in
Tanjuatco’s name. The trial court, therefore, correctly dismissed petitioner’s
In 1994, NRSI authorized Vicente P. Cuevas III, its Chairman and President, to
complaint for reconveyance.
apply on its behalf, for the acquisition of two parcels of land by virtue of its right
of accretion. Cuevas applied for the lots in his name. Then, pending approval of
the application with the Bureau of Lands, Cuevas assigned his right to
Tanjuatco. The Director of Lands approved the transfer of rights from Cuevas to
Tanjuatco.
NRSI filed an action for reconveyance against Tanjuatco. According to Tanjuatco,
it was Cuevas who was alleged to have defrauded the corporation. He averred
further that the complaint did not charge him with knowledge of the agreement
between Cuevas and NRSI.
The RTC ruled in favor of Cuevas and dismissed NRSI’s complaint and held that
Tanjuatco is an innocent purchaser for value.
ISSUE:
Whether or not Tanjuatco is the rightful owner.
RULING:
The Court ruled that Tanjuatco is the rightful owner.
An action for reconveyance is one that seeks to transfer property, wrongfully
registered by another, to its rightful and legal owner. In an action for
reconveyance, the certificate of title is respected as incontrovertible. What is
sought instead is the transfer of the property, specifically the title thereof, which
has been wrongfully or erroneously registered in another person’s name, to its
rightful and legal owner, or to one with a better right.
To warrant a reconveyance of the land, the following requisites must concur: (1)
the action must be brought in the name of a person claiming ownership or
dominical right over the land registered in the name of the defendant; (2) the
registration of the land in the name of the defendant was procured through
fraud or other illegal means; (3) the property has not yet passed to an innocent
purchaser for value; and (4) the action is filed after the certificate of title had
G.R. No. 97995 January 21, 1993 of the law as matters of equity, independently of the particular intention of the
parties.” Constructive trusts occur when “there is neither a promise nor any
PHILIPPINE NATIONAL BANK, petitioner, fiduciary relation to speak of and the so-called trustee neither accepts any trust
vs. nor intends holding the property for the beneficiary.” Following the
COURT OF APPEALS AND B.P. MATA AND CO., INC., respondents. aforementioned definitions, there is trust involved. There was no expression or
contract stipulating that Mata and PNB have a fiduciary relationship, however,
the point that there was a transaction that would infer such an arrangement
FACTS:
(payment), constructive trust has been established.
B.P. Mata & Co. Inc. (Mata), is a private corporation engaged in providing goods
The Supreme Court also adapted Art. 2154 for the case clearly falls in this article.
and services to shipping companies. Since 1966, it has acted as a manning or
Mata received money, which had not right to demand it, and there was also a
crewing agent for several foreign firms, one of which is Star Kist Foods, Inc., USA
mistake of delivery.
(Star Kist).
However, due to the prescription of Art. 2154, quasi-contract can no longer be an
However, 14 days after, PNB effected another payment in the amount of
alternative leaving constructive trust as the applicable option.
US$14,000, purporting to be another transmittal of reimbursement from Star
Kist. More than six years later, PNB requested Mata for refund of US$14,000 As for the issue whether or not PNB can still claim the $14,000, the Supreme
after it discovered its error. Court ruled that it couldn’t be possible. Even though the case is still within the
prescription period, the petitioner cannot do so because they were proved to be
PNB filed a case for collection and refund of $14,000 against Mata, arguing that
negligent in exercising their legal right. It took them seven years to realize their
based on a constructive trust under Article 1456 of Civil Code, it has a right to
error and for a big bank such as PNB, that is very remarkable. Banks are subject
recover the said amount it erroneously credited to Mata.
to audits and an error such as that should have been spotted within the year.
RTC dismissed the complaint, ruling that the case falls squarely under Article The bank should, therefore, bear the cost of its own negligence.
2154 on solutio indebiti and not under Article 1456 on constructive trust.
Appellate court affirmed such decision, adding that while Mata is duty bound to
return the amount paid by mistake, PNB’s demand for the return of US$14,000
cannot prosper because of prescription under Article 1145, stating that actions
upon a quasi-contract must be commenced within 6 years.
ISSUE:
Whether or not PNB was correct in arguing that based on constructive trust, it
can still collect the amount from Mata even after more than 6 years have already
lapsed.
RULING:
The Supreme Court applied both Art. 1456 which is on constructive trust and
Art. 2154 which is on solutio indebiti to the case.
It determined that there is constructive trust involved enforcing Art. 1456. A
constructive trust is a form of implied trust. Implied trusts are “those which,
without being expressed, are deducible from the nature of the transaction as
matters of the intent or which are superinduced on the transaction by operation
G.R. No. 159578 July 28, 2008 in favor of petitioners on May 23, 1984, Maxima had no right to sell that land as
it did not belong to her; that she conveyed nothing to petitioners; and that the
ROGELIA DACLAG and ADELINO DACLAG (deceased) Substituted by deed of sale should be declared null and void and that petitioners could not even
RODEL M. DACLAG and ADRIAN M. DACLAG, Petitioners, be considered purchasers, as they never acquired ownership of the land since
vs. the sale to them by Maxima was void.
ELINO MACAHILIG, ADELA MACAHILIG CONRADO MACAHILIG, LORENZA
HABER and BENITA DEL ROSARIO, Respondents. When the case was raised to CA, it was dismissed and the RTC ruling was
affirmed on the ground that Maxima had no right to sell the land as she was not
the rightful owner thereof, nothing was conveyed to petitioners; that a person
FACTS: who acquired property from one who was not the owner and had no right to
dispose of the same, obtained the property without right of title, and the real
Dionesio, Emeliano, Mario, Ignacio, Eusebio, Tarcela and Maxima inherited a
owner may recover the same from him.
parcel of land. The land was partitioned by them and was declared in the name
of Maxima. The land was divided between Vicenta Macahilig Galvez for the heirs ISSUE:
of Mario Macahilig, who was given the one half southern portion of the land; and
Adela Macahilig for the heirs of Eusebio Macahilig, who got the one half northern Whether or not Rogelia et al are the rightful owners.
portion.
RULING:
Maxima issued a Statement of Conformity and attested that five parcels of land
in the deed were declared in her name for taxation purposes, although said lands The Supreme Court held that the deed of sale executed by Maxima in favor of
were actually the property of her deceased parents; that she waived, renounced petitioners was null and void, since Maxima was not the owner of the land she
and relinquished all her rights to the land adjudicated to all her co-heirs in the sold to petitioners, and the one-half northern portion of such land was owned by
deed; and that she had already sold one parcel before the deed was executed, respondents. Being an absolute nullity, the deed is subject to attack anytime, in
which was considered as her advance share. Pedro Divison, Maxima's husband, accordance with Article 1410 of the Civil Code that an action to declare the
also affixed his signature to the Statement of Conformity. inexistence of a void contract does not prescribe. When there is a showing of
such illegality, the property registered is deemed to be simply held in trust for the
Maxima sold the land to spouses Daclag. Elino Macahilig, Adela Macahilig, real owner by the person in whose name it is registered, and the former then has
Conrado Macahilig, Lorenza Haber and Benita del Rosario (respondents) filed the right to sue for the reconveyance of the property. An action for reconveyance
with the Regional Trial Court a complaint for recovery of possession and based on a void contract is imprescriptible. As long as the land wrongfully
ownership, cancellation of documents and damages against Maxima and the registered under the Torrens system is still in the name of the person who
sps. Daclag. caused such registration, an action in personam will lie to compel him to
reconvey the property to the real owner. In this case, title to the property is in the
Rogelia Macahilig et al aver that they were the lawful owners and previous name of petitioner Rogelia; thus, the trial court correctly ordered the
possessors of the one half northern portion of land by virtue of a Deed of Extra- reconveyance of the subject land to respondents.
judicial Partition and that without their knowledge, Maxima illegally the land to
sps. Daclag, who are now in possession of the land. Petitioners contend that they are possessors in good faith, thus, the award of
damages should not have been imposed. They further contend that under Article
RTC Decision 544, a possessor in good faith is entitled to the fruits received before the
possession is legally interrupted; thus, if indeed petitioners are jointly and
The RTC ruled that the sale was null and void on the grounds that the land was
severally liable to respondents for the produce of the subject land, the liability
divided between the heirs of Mario and the heirs of Eusebio, with the former
should be reckoned only for 1991 and not 1984. The Supreme Court found
getting the one half southern portion and the latter the one half northern portion
partial merit in the argument. Article 528 of the Civil Code provides that
embodied in a Deed of Extra-judicial partition, which bore Maxima's
possession acquired in good faith does not lose this character, except in a case
thumbmarks. The RTC concluded that when Maxima executed the Deed of Sale
and from the moment facts exist which show that the possessor is not unaware
that he possesses the thing improperly or wrongfully. Possession in good faith
ceases from the moment defects in the title are made known to the possessors,
by extraneous evidence or by suit for recovery of the property by the true owner.
Whatever may be the cause or the fact from which it can be deduced that the
possessor has knowledge of the defects of his title or mode of acquisition, it must
be considered sufficient to show bad faith. Such interruption takes place upon
service of summons.
Article 544 of the Civil Code provides that a possessor in good faith is entitled to
the fruits only so long as his possession is not legally interrupted. Records show
that petitioners received a summons together with respondents’ complaint on
August 5, 1991; thus, petitioners’ good faith ceased on the day they received the
summons. Consequently, petitioners should pay respondents 10 cavans of palay
per annum beginning August 5, 1991 instead of 1984.
G.R. No. 163876 July 9, 2008 Garcia did not in any way establish that Felipe did indeed donate the subject lot
to them. Also, Simeon could not have conveyed the said lot as he was not its
ROSALINA CLADO-REYES, ALICIA REYES-POTENCIANO, ANTONIO C. owner.
REYES, BERNARDO C. REYES, JOVITO C. REYES, MARIA REYES-DIZON,
BERNARDA REYES-LLANZA, deceased represented by BONG R. LLANZA ISSUE
and REYNALDO C. REYES (deceased), represented by NINO R.
REYES, Petitioners, Whether or not the petitioners’ Certification and Pagpapatunay are sufficient to
vs. cast doubt on the respondents’ title to the disputed land.
SPOUSES JULIUS and LILY LIMPE, Respondents.
RULING
FACTS
Under Articles 476 and 477 of the New Civil Code, there are two indispensable
Petitioners aver that they have been occupying the lot in Guiguinto, Bulacan requisites in order that an action to quiet title could prosper, to wit: that the
covered by TCT No. RT-32498 since 1945 through their predecessor-in-interest plaintiff or complainant has a legal or an equitable title to or interest in the real
Mamerto Reyes. Allegedly, Mamerto, a former tenant of Felipe Garcia, accepted a property subject of the action and that the deed, claim, encumbrance or
verbal promise made by the latter to give the subject lot to the former in proceeding claimed to be casting cloud on his title must be shown to be in fact
exchange for the surrender of his tenancy rights as its tiller. In support of their invalid or inoperative despite its prima facie appearance of validity or legal
allegations, the petitioners presented two documents, to wit, a Certification and a efficacy.
Pagpapatunay said to be executed by Simeon Garcia, son of Felipe. They also
The documentary evidence did not confirm their title over the land as those were
alleged that whenever respondents visited the lot, respondent Julius Limpe used
purely hearsay considering that the original copies thereof and the person who
to promise to deliver the certificate of title to them. However, sometime in
executed the same was not presented in court to verify its authenticity.
October 1994, respondents asserted ownership over the disputed lot through a
Meanwhile, the evidence of the respondents clearly established their ownership
letter sent to the petitioners.
over the disputed land because, these were all registered and made in their
The respondents insisted that they are the legal owners of the lot by virtue of a names; there is a presumption of validity of a Torrens Certificate of Title which is
Deed of Exchange of Real Estate and Deed of Absolute Sale between them and also the best proof of ownership of a lot; plus the fact that realty tax payments is
Farm-Tech Industries, Incorporated (FTII). Furthermore, they exhibited TCT No. proof that the holder has a claim of title over the property.
T-199627, Tax Declaration Nos. 15172 and 9529 and realty tax receipts of the
lot, which were all registered and declared in their names. They maintained that
as buyers in good faith of the disputed lot from FTII, they are not obliged to go
beyond the face of a TCT in the absence of any cloud therein. Moreover,
petitioners’ allegations deserve scant consideration in view of the fact that they
failed to present Simeon in court to testify on the veracity of the contents of the
documents and neither was the said property particularly described in the
Pagpapatunay as the disputed realty .
The trial court favored the respondents saying that the certificate of title, tax
declarations, and realty tax receipts indisputably established the respondents’
ownership over the lot over the petitioners’ allegation of an “undocumented
promise” which in law is unenforceable, hence it ordered the reconveyance of the
lot to respondents. The Court of Appeals affirmed the ruling of the lower court
holding that the petitioners have no title thereto which can cast a cloud on the
title of the respondents since the documents allegedly executed by Simeon
G.R. No. 168661 October 26, 2007 the land registration court did not have jurisdiction to adjudicate inalienable
lands, thus the decision adjudicating the subject parcel of land to Fermina
ESTATE OF THE LATE JESUS S. YUJUICO, represented by Castro was void. And third, the titles of Yujuico and Carpio, being derived from a
ADMINISTRATORS BENEDICTO V. YUJUICO and EDILBERTO V. YUJUICO; void title, were likewise void.
and AUGUSTO Y. CARPIO, Petitioners,
vs. Trial Court ruled in favor of the petitioner and states that after 28 years without
REPUBLIC OF THE PHILIPPINES and the COURT OF being contested, the case had already become final and executory. The trial
APPEALS, Respondents. court also found that the OSG had participated in the LRC case, and could have
questioned the validity of the decision but did not.
FACTS:
On appeal, reversed the decision of the lower court asserting that shores are
In 1973, Fermina Castro filed an application for the registration and confirmation properties of the public domain intended for public use and, therefore, not
of her title over a parcel of land in Court of First Instance of Pasig-Rizal (CFI). The registrable and their inclusion in a certificate of title does not convert the same
application was opposed by the Office of the Solicitor General (OSG) on behalf of into properties of private ownership or confer title upon the registrant. Further,
the Director of Lands, and by Mercedes Dizon, a private party. Trial court ruled according to the appellate court res judicata does not apply to lands of public
in favor of Castro. domain, nor does possession of the land automatically divest the land of its
public character.
The Director of Lands and Mercedes Dizon did not appeal from the adverse
decision of the Pasig-Rizal CFI. Thus, the order for the issuance of a decree of ISSUE:
registration became final, and a Decree was issued by the Land Registration
Commission (LRC). An Original Certificate of Title was issued in the name of Whether or not the Antipolo Land Registration Court has jurisdiction over the
Fermina Castro by the Register of Deeds. alleged public lands
Land was then sold to Jesus Yujuico. The OCT of Castro was cancelled and a RULING:
TCT was issued in Yujuico’s name over Lot1 while another TCT was issued in
favor of herein co-petitioner Augusto Carpio. The Court ruled that the CFI-Pasig Rizal under Section 14 of PD 1529 (Property
Registration Decree) has jurisdiction over applications for registration of title to
Meanwhile, PD no. 1085 was issued and asserts that Land reclaimed in the land.
foreshore and offshore areas of Manila Bay became the properties of the Public
Estates Authority (PEA), a government corporation that undertook the Section 14 of PD 1592 provides the the following persons may file in the proper
reclamation of lands or the acquisition of reclaimed lands. Thus, an OCT was Court of First Instance an application for registration of title to land, whether
issued in favor of PEA. The PEA also acquired ownership of other parcels of land personally or through their duly authorized representatives:
along the Manila Bay coast which were subsequently sold to the Manila Bay
(1) Those who by themselves or through their predecessors-in-interest have been
Development Corporation (MBDC).
in open, continuous, exclusive and notorious possession and occupation of
The PEA undertook the construction of the Manila Coastal Road. As this was alienable and disposable lands of the public domain under a bona fide claim of
being planned, Yujuico and Carpio discovered that a verification survey they ownership since June 12, 1945, or earlier.
commissioned showed that the road directly overlapped their property, and that
Conformably, the Pasig-Rizal CFI, Branch XXII has jurisdiction over the subject
they owned a portion of the land sold by the PEA to the MBDC.
matter of the land registration case filed by Fermina Castro, petitioners’
Yujuico and Carpio filed before the Parañaque City Regional Trial Court (RTC), a predecessor-in-interest, since jurisdiction over the subject matter is determined
complaint for the Removal of Cloud and Annulment of Title with Damages. by the allegations of the initiatory pleading of the application. Settled is the rule
that "the authority to decide a case and not the decision rendered therein is what
Respondent Republic argued that, first, since the subject land was still makes up jurisdiction. When there is jurisdiction, the decision of all questions
underwater, it could not be registered in the name of Fermina Castro. Second, arising in the case is but an exercise of jurisdiction."
The land registration court initially has jurisdiction over the land applied for at
the time of the filing of the application. After trial, the court, in the exercise of its
jurisdiction, can determine whether the title to the land applied for is registrable
and can be confirmed. In the event that the subject matter of the application
turns out to be inalienable public land, then it has no jurisdiction to order the
registration of the land and perforce must dismiss the application.
