Heirs of Revilleza v. Heirs of Tamisin
REITERATIONFacts
The Antecedents: The land in question was originally owned by Ignacio Revilleza, who died intestate. An Extrajudicial Partition was executed among his heirs and Antonio Tamisin. Subsequently, an "Escritura de Venta Absoluta" dated October 8, 1921, allegedly conveyed portions of the land to Sebastian Salva Cruz and Lorenzo Revilleza. Sebastian Salva Cruz declared the land for taxation and paid realty taxes thereon. Lorenzo Revilleza's heir, Emilio Revilleza, applied for registration of the second half of the land, leading to the issuance of OCT RO-1100 (No. 9423) in the names of Emilio, Macario, Marcela Revilleza, and Maria R. Vda. de Vega. Maria R. Vda. de Vega later adjudicated the land to herself, resulting in TCT No. 3911 in her name. Private respondents, heirs of Antonio Tamisin, filed a criminal complaint for falsification against Sebastian Salva Cruz when a certification from the Bureau of Records Management failed to reveal the existence of the "Escritura de Venta Absoluta." The criminal complaint was not pursued due to Antonio Tamisin's death. Procedural History: Private respondents filed a complaint for annulment of documents, reconveyance, and damages, later amended to reconveyance and damages. The trial court dismissed the complaint and intervention for failure to establish claims by preponderance of evidence, ordering plaintiffs and intervenors to pay attorney's fees. The Court of Appeals reversed the trial court's decision, ordering defendants-appellees to reconvey ownership and possession of the land to plaintiffs-appellants and to pay attorney's fees. The motion for reconsideration was denied. The Petition: Petitioners seek reversal of the Court of Appeals' decision, alleging that private respondents failed to identify the property, that the cause of action for reconveyance had prescribed, that petitioners acquired ownership by extraordinary prescription, that the deed of sale was genuine, that there was no implied trust, and if there was, it was repudiated and prescription set in.
Issue(s)
Whether or not the land in question was identified by private respondents. Whether or not private respondents' action before the trial court was mainly for annulment of document (with reconveyance as a necessary consequence), which is imprescriptible, or for reconveyance, which is subject to prescription.
Ruling
The petition is GRANTED. The decision of the Court of Appeals is SET ASIDE, and the decision of the Regional Trial Court is REINSTATED. The action for reconveyance filed by private respondents has prescribed.
Ratio Decidendi
On the issue of land identification: The Supreme Court adopted the ruling of the Court of Appeals, stating that the defendants-appellees' claim of acquiring the land through the "Escritura de Venta Absoluta" inherently identified the property being sought by the plaintiffs-appellants. Furthermore, Maria R. Vda. de Vega's own averment in her answer that her property was "WELL DEFINED by metes and bounds" indicated her knowledge of the specific parcel of land being claimed by private respondents. Therefore, the conclusion that private respondents failed to identify the property was unwarranted. On the nature and prescription of the action: The Supreme Court found that the Court of Appeals resorted to a strained application of Article 1410 of the Civil Code. The action filed by private respondents before the trial court was for reconveyance with damages based on an implied or constructive trust, as evidenced by the allegations in their complaint and their prayer for relief. The "Escritura de Venta Absoluta" was not mentioned in the original complaint. The Court reiterated the established rule that an action for reconveyance based on an implied or constructive trust prescribes in ten (10) years. The action against the heirs of Maria R. Vda. de Vega should have been brought within ten years from May 20, 1929 (issuance of OCT RO-1100), and against the heirs of Sebastian Salva Cruz within ten years from 1945 (when Sebastian Salva Cruz allegedly refused to return the land). Since the amended complaint for reconveyance and damages was filed on October 14, 1974, the action had long prescribed. Therefore, the trial court's dismissal of the complaint was correct, albeit based on the ground of prescription rather than failure to establish claims by preponderance of evidence.
Main Doctrine
An action for reconveyance based on an implied or constructive trust prescribes in ten (10) years. The purpose of an action is determined by the allegations in the complaint and the prayer for relief, not by arguments made in briefs.