Millena v. Court of Appeals
REITERATIONFacts
The Antecedents: This case concerns a 3,934-square meter parcel of land, originally part of a larger 14,284-square meter lot (Lot 1874) subject to a cadastral proceeding in the 1920s. A compromise agreement in 1926 divided Lot 1874, with Gregoria Listana receiving approximately one-fourth (3,934 sq. meters) and Potenciana Maramba and her children receiving the remaining three-fourths. Gregoria Listana, gravely ill, executed a power of attorney authorizing her cousin, Antonio Lipato, to sell her portion to cover interment expenses. Lipato sold the land to Gaudencio Jacob on October 23, 1926, the same day Gregoria Listana died. Gaudencio Jacob took possession and harvested coconuts, leading to an ejectment suit by Potenciana Maramba, which was dismissed as Gaudencio possessed a valid sale document. Gaudencio Jacob and his successors, including respondent Felisa Jacob, maintained continuous possession for decades, with Felisa Jacob having the portion adjudicated to her in 1966 and paying taxes. Procedural History: In November 1981, Felisa Jacob discovered that Florencio Listana, son of Potenciana Maramba, had obtained Free Patent Certificate of Title No. VH-23536 in 1980 for the entire Lot 1874, including her portion. Jacob filed a protest with the Bureau of Lands, alleging misrepresentation and deceit. Despite this, the heirs of Florencio Listana sold the entire Lot 1874 to petitioner Alejandro Millena in 1986, who was issued Transfer Certificate of Title No. T-71657. Consequently, Felisa Jacob filed a complaint for annulment of title with preliminary injunction and damages, later amended to include reconveyance, before the Regional Trial Court (RTC). The RTC ordered Millena to reconvey the 3,934-square meter portion to Jacob and awarded attorney's fees. Millena appealed to the Court of Appeals (CA), which affirmed the RTC's decision but deleted the attorney's fees. After the CA denied his motion for reconsideration, Millena filed the present petition. The Petition: Petitioner Alejandro Millena seeks review of the Court of Appeals' decision, raising three main issues: (1) whether prescription has barred the action for reconveyance, arguing that the action filed in 1992 was too late given the title was procured in 1980; (2) whether the documents and evidence used by the CA, including a compromise agreement, a Justice of the Peace decision, a power of attorney, and a deed of sale, were duly authenticated and proven by the respondent; and (3) whether the CA correctly affirmed the RTC's order of reconveyance. Millena contends that the lower courts failed to address the issue of prescription and that the evidence supporting Felisa Jacob's claim lacks proper authentication. He also argues he is an innocent purchaser for value and that the action for reconveyance should not prosper against him.
Issue(s)
Whether prescription has barred the action for reconveyance. Whether the documents and evidence used by the Court of Appeals were duly authenticated and proved by the private respondent. Whether the respondent appellate court correctly affirmed the order of reconveyance by the trial court.
Ruling
The petition is DENIED. The assailed Decision of the Court of Appeals and its Resolution denying the motion for reconsideration are AFFIRMED. Petitioner Alejandro Millena is ORDERED to reconvey within thirty (30) days from the finality of this Decision that northern portion in question of Lot 1874 consisting of 3,934 square meters in favor of private respondent Felisa Jacob.
Ratio Decidendi
On the issue of prescription: The Court reiterated that an action for reconveyance can be barred by prescription, with fraud-based actions prescribing in four years from discovery (issuance of title) and implied trust-based actions prescribing in ten years from the issuance of title. However, prescription cannot be invoked when the plaintiff is in possession of the land to be reconveyed. The Court found that Felisa Jacob exercised dominion over the contested parcel, meeting the elements of possession through her caretaker, declaration of ownership, and payment of property taxes since 1967. Therefore, prescription was not a valid defense against her claim. On the authenticity and proof of documents: The Court held that questions of authenticity of documents are questions of fact, and it generally does not disturb the findings of the Court of Appeals. However, for substantial justice, it examined the issues. The Court found the Justice of the Peace decision dated December 31, 1926, to be genuine, being a public document admissible without further proof. This decision, penned in Spanish, bore the court's seal and an attestation of its authenticity. Petitioner failed to present evidence to prove its spurious character. The pronouncements within this decision confirmed the existence of the compromise agreement, power of attorney, and deed of sale, which, having become final, were conclusive as to the facts therein. On the affirmation of the reconveyance order: The Court affirmed that while a decree of registration is generally final, the law allows an action for reconveyance to protect aggrieved parties from fraud, provided the property has not been transferred to an innocent purchaser for value. Felisa Jacob presented evidence of ownership, including continuous possession since 1966, her predecessor's lawful possession since 1926, and tax declarations. The Court found that the inclusion of Felisa's portion in Florencio Listana's Free Patent Certificate Title was erroneous. Furthermore, Alejandro Millena could not claim to be an innocent purchaser for value. Evidence showed he lived adjacent to the contested lot for years before his purchase, would have seen Felisa's caretaker working on the land, and was aware of Felisa's protest filed in 1981. These circumstances were sufficient to arouse his curiosity and prompt inquiry into the sellers' title, negating his claim of good faith.
Main Doctrine
Prescription cannot be invoked in an action for reconveyance when the plaintiff is in possession of the land to be reconveyed. Furthermore, a purchaser cannot be considered an innocent purchaser for value if circumstances exist that would have prompted a prudent buyer to inquire into the genuineness of the seller's title.