Sinaon v. Soroñgon
REITERATIONFacts
The Antecedents: Canuta Soblingo was adjudicated Lot No. 4781 of the Sta. Barbara, Iloilo cadastre with an area of 5.5 hectares, and OCT No. 6178-A was issued in her name in 1917. In 1923, Canuta sold the lot to spouses Patricio Sinaon and Julia Sualibio for P2,000, and TCT No. 2542 was issued to them. The Sinaon spouses and their children declared the lot for tax purposes in Sinaon's name and paid the realty taxes thereon, possessing the land as owners from 1923 up to the present, a period of more than half a century. Julia Sualibio was the granddaughter of Canuta. Procedural History: Respondents Soroñgon, et al., heirs of the other children of Domingo Somblingo (alleged original owner), filed a second amended complaint in 1968 (action filed in 1964) claiming that Canuta and the Sinaons were trustees of the lot and that they are entitled to a 4/5 share thereof. The trial court and the Court of Appeals sustained this theory, ordering the Sinaons to convey 4/5 of the lot to the respondents and decreeing partition. The Petition: The Sinaons appealed to the Supreme Court, arguing that their title had become indefeasible after more than forty years of being registered owners and possessing the land as owners for over half a century.
Issue(s)
Whether an action for reconveyance of registered land based on implied trust would lie after the supposed trustees had held the land for more than forty years. Whether the action for reconveyance was barred by prescription.
Ruling
The judgment of the Court of Appeals is reversed, and the complaint is dismissed. The receivership is terminated, and the receiver is directed to wind up his accounts.
Ratio Decidendi
On the issue of whether an action for reconveyance of registered land based on implied trust would lie after the supposed trustees had held the land for more than forty years: The Supreme Court held that after the Sinaons had appeared as registered owners of the lot for more than forty years and had possessed it during that period, their title had become indefeasible and their possession could not be disturbed. Any pretension as to the existence of an implied trust should not be countenanced. The Court emphasized that the trustors, who allegedly created the trust, died a long time ago, and the attempt to prove the trust was made through unreliable oral evidence. The title and possession of the Sinaons, supported by documentary evidence, cannot be defeated by oral evidence which can be easily fabricated and contradicted. The Court noted that there was no express trust, as express trusts concerning real property cannot be proven by parol evidence. Furthermore, an implied trust cannot be established contrary to the recitals of a Torrens title upon vague and inconclusive proof. On the issue of whether the action for reconveyance was barred by prescription: The Supreme Court ruled that even assuming that an implied trust existed, the plaintiffs' action was clearly barred by prescription. Prescription is regarded as a statute of repose, designed to suppress fraudulent and stale claims that arise after the facts have become obscure due to the lapse of time, defective memory, or death or removal of witnesses. The Court stated that it was not necessary for the Sinaons to plead prescription as a defense because there was no dispute as to the dates and no factual issue regarding prescription. The Court also invoked the ruling in Gerona vs. De Guzman that an action for reconveyance of realty based upon a constructive or implied trust resulting from fraud may be barred by prescription, with the prescriptive period reckoned from the issuance of the title which operates as constructive notice. The supposed trust in this case was classified as a constructive trust arising by operation of law, not a trust in the technical sense.
Main Doctrine
An action for reconveyance of registered land based on implied trust, where the supposed trustees have held the land as registered owners for more than forty years and have possessed it as owners for more than half a century, is barred by prescription and cannot be countenanced, as the title has become indefeasible and possession cannot be disturbed.