Canete v. Benedicto
REITERATIONFacts
The Antecedents: Plaintiffs, heirs of spouses Tomas Canete and Teodora Jison, filed a complaint to annul the Torrens title of Gabriel Benedicto over Lot No. 757, an area of over twenty-eight hectares. They alleged that the Canete spouses originally owned the lot, possessing and cultivating it until the war. After the war, Benedicto allegedly occupied it, judicially reconstituted the Torrens title in his name, and refused to return the property despite demands. Procedural History: The Court of First Instance (CFI) of Negros Occidental dismissed the complaint on the ground of prescription. The plaintiffs appealed, and the Court of Appeals certified the case to the Supreme Court as it involved a question of law. The Petition: The plaintiffs prayed for the cancellation of Benedicto's title, reissuance of the original certificate of title in their names, an accounting of fruits, delivery of physical possession, attorney's fees, and settlement of Benedicto's mortgage obligation to the Philippine National Bank.
Issue(s)
Whether the trial court erred in requiring Benedicto to submit documents proving his title. Whether the trial court erred in regarding Benedicto's documents as authentic without allowing plaintiffs to controvert them. Whether the action for annulment of title and recovery of possession had prescribed.
Ruling
The Supreme Court affirmed the orders of the trial court dismissing the complaint, holding that the action was barred by prescription.
Ratio Decidendi
On the issue of requiring Benedicto to submit documents: The Court held that the trial court acted properly in directing Benedicto to submit documents supporting his title, as the case could be disposed of based on documentary evidence. The plaintiffs had the opportunity to controvert these documents but failed to do so. On the issue of regarding documents as authentic: The Court found that the plaintiffs were furnished copies of Benedicto's manifestation and annexes, and they did not oppose them nor appear at the hearing. They also failed to present countervailing evidence in their comments or subsequent motions. Therefore, the trial court did not err in considering the defendant's evidence as uncontradicted. On the issue of prescription: The Court agreed with the trial court that the action was barred by prescription. Benedicto's reconstituted title was issued on July 13, 1964, implying his original title (TCT No. 4169) existed even earlier. Tax declarations in Benedicto's name dated 1926, 1948, and 1951 further supported his claim of ownership. The property was mortgaged to the Philippine National Bank (PNB), foreclosed, and then Benedicto repurchased it through a Deed of Promise to Sell dated August 7, 1955, and a Deed of Absolute Sale from PNB on August 6, 1963. The Court noted that the plaintiffs' predecessors-in-interest had not challenged Benedicto's title or possession since at least 1926, or when ownership vested in PNB in 1955. The complaint was filed on June 19, 1974, which was more than ten years after Benedicto acquired ownership from PNB in 1963, and even longer from when his title was reconstituted in 1964. The Court reiterated that an action for recovery of title or possession of real property must be brought within ten (10) years after the cause of action accrues, citing numerous precedents. Prescription is considered a statute of repose to prevent stale and fraudulent claims.
Main Doctrine
An action for annulment of title and recovery of possession of real property is barred by prescription if not filed within ten (10) years from the accrual of the cause of action, considering that prescription is a statute of repose designed to suppress fraudulent and stale claims.