Sta. Ana, Jr. v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Pablo Sta. Ana, Jr. and his deceased mother, Socorro Sta. Ana, filed an action for reconveyance against spouses Ernesto and Leonor Cayetano and Alejandro B. Manahan concerning a 900 square-meter parcel of land. They alleged that the spouses Cayetanos fraudulently included the subject land in their registration proceedings for two other lots, despite petitioner and his mother's continuous possession since 1951. The spouses Cayetanos obtained OCT No. 989 over the subject land on March 26, 1962, and subsequently sold it to Manahan, who was issued TCT No. 17218 on August 17, 1973. Petitioner and his mother prayed for the cancellation of Manahan's title, segregation of the subject land, and reconveyance to them, with damages. A complaint in intervention was filed by Asteria Maulauen with similar allegations. Procedural History: Private respondents filed a motion to dismiss based on prescription, arguing that the action, filed on August 27, 1973, was filed 11 years and 5 months after the registration of OCT No. 989 on March 26, 1962, exceeding the 10-year prescriptive period for actions based on implied or constructive trust. The trial court deferred resolution, and trial ensued. The trial court appointed a commissioner for a relocation survey. Upon submission of the commissioner's report, private respondents again moved to dismiss based on prescription. The trial court rendered a decision dismissing petitioner's complaint and Maulauen's complaint in intervention, declaring Manahan the rightful owner and ordering petitioner to surrender possession. The Court of Appeals affirmed the trial court's decision. The Petition: Petitioner argues that the Court of Appeals erred in disregarding his continuous possession, in not applying the doctrine that an action for reconveyance seeking to quiet title is imprescriptible when filed by one in possession, in ignoring the Commissioner's Report, and in affirming the award of affirmative relief not raised in the pleadings.
Issue(s)
Whether the Court of Appeals erred in disregarding the uncontroverted fact of petitioner's open and continuous possession in the concept of owner; and whether the Court of Appeals erred in not applying the doctrine that an action for reconveyance seeking to quiet title is imprescriptible if filed by one in possession. Whether the Court of Appeals erred in ignoring the Commissioner's Report. Whether the Court of Appeals erred in affirming the trial court's award of affirmative relief not raised in the pleadings.
Ruling
The petition has no merit. Both the trial court and the Court of Appeals correctly found that petitioner's action for reconveyance has prescribed. The petition is denied, and the decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of prescription of the action for reconveyance: The Court held that the action for reconveyance, based on the allegations in the complaint, is founded on an implied or constructive trust. Such an action prescribes in ten (10) years. The filing of the complaint on August 27, 1973, which was eleven (11) years and five (5) months after the registration of OCT No. 989 on March 26, 1962, was therefore filed beyond the prescriptive period. The Court reiterated the well-settled jurisprudence that an action for reconveyance based on an implied or constructive trust must prescribe in ten (10) years. Petitioner cannot escape prescription by arguing that his action is one for quieting of title, which is imprescriptible, because his complaint explicitly alleged that the property was "in trust for the plaintiffs." A party is bound by the theory adopted in their pleadings and cannot change it on appeal. The Court emphasized that a party cannot repudiate their theory and cause of action after having lost on that basis. The prescriptive period for an action for reconveyance based on an implied or constructive trust commences from the issuance of the Torrens title over the property, not from the discovery of the adverse claim or the issuance of a transfer certificate of title. Therefore, the reckoning date for prescription was March 26, 1962, the date OCT No. 989 was issued. On the issue of possession and the Commissioner's Report: As the issue of prescription was determinative of the case, the Court found it unnecessary to discuss the other assigned errors, including those pertaining to possession and the Commissioner's Report. The resolution of the prescription issue rendered the other assigned errors moot and academic. The Court's affirmation of the lower courts' findings on prescription meant that the petitioner's claims regarding possession and the report were not given weight in light of the prescriptive bar. The Court did not explicitly address this issue, as the issue of prescription was determinative of the case.
Main Doctrine
An action for reconveyance based on an implied or constructive trust prescribes in ten (10) years from the issuance of the Torrens title over the property.