Alzona v. Capunitan
REITERATIONFacts
The Antecedents: Plaintiffs instituted an action to recover two registered parcels of land (Lots Nos. 2968 and 2524) and to cancel the certificates of title in the names of defendants Gregoria Capunitan and Manuel Reyes, seeking the issuance of new titles in their names. The defendants raised the special defenses of estoppel and prescription of action. Procedural History: The Court of First Instance (CFI) of Laguna dismissed the complaint on grounds of estoppel and prescription. Upon appeal, the Court of Appeals (CA) found that the parcels of land were conjugal properties of Arcadio Alomia and Ildefonsa Almeda. Upon Arcadio's death, one-half belonged to Ildefonsa and the other half was inherited by the plaintiffs as Arcadio's nephews and nieces. The CA found that Ildefonsa committed legal fraud by claiming to be Arcadio's sole heir to obtain the transfer of Lot 2524 to her name, holding the plaintiffs' share in trust. The CA remanded the case to the CFI for reception of further evidence on whether the defendants recognized the plaintiffs' title and promised reconveyance, and whether a third suit was filed in 1938 and was pending liberation. After a new trial, the CFI again dismissed the complaint, upholding its initial decision that the cause of action had prescribed. The plaintiffs appealed directly to the Supreme Court on purely legal questions. The Petition: Plaintiffs-appellants argued that registered property rights are imprescriptible and that since Ildefonsa held the property in trust, the defendants, who purchased with knowledge, also held it in trust, making the beneficiaries' action imprescriptible.
Issue(s)
Whether the action for reconveyance of registered property, based on an implied trust, is imprescriptible. Whether the filing of previous dismissed suits interrupted the prescriptive period. Whether the defendants, as purchasers with knowledge of the trust, are also bound by the trust and their action is imprescriptible.
Ruling
The Supreme Court affirmed the decision of the lower court, holding that the action for reconveyance had prescribed. The Court ruled that while no title to registered land can be acquired by prescription against the registered owner, the plaintiffs were not the registered owners. The Court found that the sale by Ildefonsa to the defendants was voidable, not void, and thus subject to prescription. The Court also found that the plaintiffs' previous suits were dismissed without interruption of the prescriptive period, and that the defendants had consistently repudiated the trust.
Ratio Decidendi
On whether the action for reconveyance of registered property, based on an implied trust, is imprescriptible: The Court clarified that while Section 46 of the Land Registration Act provides that no title to registered land can be acquired by prescription against the registered owner, this protection is only for the benefit of registered owners. Since the plaintiffs were not the registered owners, they could not invoke this provision. The Court distinguished this case from Eugenio and Guinoo, where the plaintiffs were considered continuations of the personality of the decedents whose properties were registered in their parents' names. In this case, the lands were registered in the names of Arcadio Alomia and his widow Ildefonsa Almeda, and subsequently in the names of the defendants. The Court held that the action for reconveyance based on an implied or constructive trust prescribes in ten (10) years, citing established jurisprudence. On whether the filing of previous dismissed suits interrupted the prescriptive period: The Court found that the plaintiffs had filed two previous suits (Civil Case No. 5340 in 1929 and Civil Case No. 5657 in 1931), both of which were dismissed due to the non-appearance of parties or failure to comply with court orders. The Court found no evidence that these dismissals were due to amicable settlements or promises of reconveyance by the defendants. The Court also found no evidence of a third suit filed in 1938. Therefore, these dismissals did not interrupt the prescriptive period. The Court noted that the defendants had consistently repudiated the trust. The filing of the present action in 1949 or 1950, long after the accrual of the cause of action in 1928, meant that the action had long prescribed. On whether the defendants, as purchasers with knowledge of the trust, are also bound by the trust and their action is imprescriptible: The Court acknowledged that the defendants purchased the lots with knowledge of their conjugal nature and that Ildefonsa held a portion in trust for the plaintiffs. However, the Court reiterated that the sale by Ildefonsa to the defendants was not void or inexistent, but at most voidable. As a voidable contract, it is valid until revoked within the prescribed period. Therefore, the action for reconveyance was subject to prescription. The Court further stated that the defendants, being third persons who repudiated the trust and claimed ownership, also acquired the properties by prescription, citing Tolentino vs. Vitug and Government of the Philippines vs. Abadilla.
Main Doctrine
An action for reconveyance based on an implied or constructive trust prescribes in ten (10) years. The filing of successive suits that are dismissed due to non-appearance or failure to comply with court orders does not interrupt the prescriptive period, especially when the defendants have consistently repudiated the trust and claimed ownership.