Bejoc v. Cabreros
REITERATIONFacts
The Antecedents: Maura Caputol executed a deed of donation inter vivos in favor of her son, Domingo Cabreros, on November 7, 1975. Domingo and his wife, respondent Prima Cabreros, took possession of the lots and had the tax declarations transferred to their names. Petitioners, spouses Jose and Jovita Bejoc, were left as caretakers when Maura and Domingo migrated to Hawaii. Petitioners were tasked to deliver harvests to respondent Prima's mother and pay taxes from the proceeds. Domingo died in 1979, succeeded by respondent Prima and their minor daughter. In October 1989, respondent Prima visited the Philippines and heard rumors of petitioners exercising acts of ownership. Upon confrontation, petitioners initially denied but later claimed Maura Caputol gave the properties to them. Maura denied this, stating she had already donated the properties to Domingo in 1975. Respondent Prima discovered petitioners stopped delivering harvests in 1984 and that tax declarations in Domingo's name were cancelled and reissued in Maura Caputol's name based on a quitclaim allegedly executed in 1971. Subsequently, these were cancelled and reissued in petitioner Jovita Caputol's name based on a deed of confirmation of sale dated May 18, 1984, allegedly executed by Maura Caputol. Petitioners also applied for a free patent, leading to the issuance of Original Certificate of Title (OCT) No. 26947 to petitioner Jose Bejoc on October 17, 1984. Procedural History: Respondent Prima filed an action for reconveyance against petitioners on February 1, 1990, before the Regional Trial Court (RTC). Petitioners alleged they were administrators since 1974 and owners since 1978, claiming Maura Caputol sold the properties to them in 1978, confirmed in 1984. They also argued the action was barred by prescription. The RTC ruled in favor of the respondent, declaring her the lawful owner and ordering reconveyance. The Court of Appeals affirmed the RTC's decision, and a motion for reconsideration was denied. The Petition: Petitioners filed a petition for review under Rule 45, assailing the Court of Appeals' decision and resolution, arguing that their action for reconveyance was barred by prescription.
Issue(s)
Whether the respondent's action for reconveyance has prescribed. Whether an implied or constructive trust was created in favor of the respondent.
Ruling
The petition is denied. The assailed decision and resolution of the Court of Appeals are affirmed in toto. Costs against petitioners.
Ratio Decidendi
On the issue of prescription: The Court held that the action for reconveyance was based on an implied or constructive trust, not exclusively on fraud. Citing Article 1456 of the Civil Code, the Court explained that a constructive trust arises when property is acquired through mistake or fraud, making the acquirer a trustee for the benefit of the person from whom the property comes. The prescriptive period for an action for reconveyance based on an implied or constructive trust is ten (10) years. This period is reckoned from the date of the issuance of the original certificate of title or transfer certificate of title, as such issuance operates as a constructive notice to the whole world. In this case, the OCT was issued on October 17, 1984, and the action for reconveyance was filed on February 1, 1990, well within the ten-year prescriptive period. The petitioners' contention that the prescriptive period should be four years based on fraud was rejected because the underlying basis of the action was the breach of trust, not merely the fraud in obtaining the title. The Court reiterated the principle that the rule on indefeasibility of title cannot be used for the perpetration of fraud against the real owner, and that the statute of limitations will not apply where the registered owner knew that the land actually belonged to another person. On the existence of an implied or constructive trust: The Court found no error in the lower courts' findings that an implied trust was created. The evidence showed that while the properties were under the administration of the petitioners, they transferred the tax declarations from Domingo Cabreros to Maura Caputol based on a fake quitclaim, and subsequently to petitioner Jovita Caputol based on a fraudulent deed of confirmation of sale. Maura Caputol denounced these documents as spurious, asserting she had already donated the properties to her son Domingo in 1975 and could not have sold them later. The Court noted that Maura Caputol was elderly at the time of the alleged confirmation of sale and could have been manipulated. Furthermore, the petitioners failed to present the alleged deed of sale and quitclaim, which was fatal to their claim. The issuance of the free patent and OCT in petitioner Jose Bejoc's name was deemed a flagrant breach of the confidence reposed in them, as they knew the properties were not theirs and had acted as mere overseers. The Court emphasized that possession of a certificate of title is not conclusive of ownership if the land was illegally or erroneously included.
Main Doctrine
An action for reconveyance based on an implied or constructive trust prescribes in ten (10) years from the date of the issuance of the original certificate of title or transfer certificate of title, as such issuance operates as constructive notice to the whole world.