Brito v. Dianala
REITERATIONFacts
The Antecedents: The case involves a parcel of land, a portion of Lot No. 1536-B, originally owned by Esteban Dichimo and Eufemia Dianala. In 1976, heirs of Vicente Dichimo (including Margarita Dichimo, wife of petitioner Ramon B. Brito, Sr.) and heirs of Eusebio Dichimo filed a complaint for recovery of possession against Jose Maria Golez. Respondents, claiming to be heirs of Esteban and Francisca Dumalagan (Esteban's first wife), filed an Answer-in-Intervention, asserting their prior possession and superior legal interest. The trial court dismissed their intervention without prejudice for failure to secure counsel. Subsequently, a Compromise Agreement was approved, dividing Lot No. 1536-B between Golez and the heirs of Vicente (Margarita, Bienvenido, and Francisco). TCT No. T-12561 was issued in their names. Procedural History: In 1999, petitioner and his co-heirs filed a complaint for recovery of possession against respondents (Civil Case No. 548-C). Respondents, in turn, filed a complaint for reconveyance and damages against petitioner and his co-heirs (Civil Case No. 588-C). The RTC dismissed Civil Case No. 548-C for forum shopping and Civil Case No. 588-C for want of jurisdiction. The CA set aside the RTC's Joint Orders dismissing Civil Case No. 588-C and remanded the case for trial on the merits. The CA denied petitioner's motion for reconsideration. The Petition: Petitioner seeks to annul the CA's Decision and Resolution, arguing that the lower court had no jurisdiction to hear the reconveyance case and that the amendment of the decision in Civil Case No. 12887 was tantamount to annulment.
Issue(s)
Whether the Court of Appeals erred in ruling that the lower court has jurisdiction to hear the reconveyance case. Whether the Court of Appeals erred in finding that the amendment of the decision in Civil Case No. 12887 is not tantamount to annulment of the said decision; and whether the reconveyance case is barred by prescription or laches.
Ruling
The petition is DENIED. The assailed Decision and Resolution of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the jurisdiction to hear the reconveyance case: The Court held that respondents were not bound by the judgment in Civil Case No. 12887 because their Answer-in-Intervention was dismissed without prejudice, rendering them strangers to the case. Consequently, they lost their standing in court and were not afforded the opportunity to present evidence or participate in the compromise agreement. The dismissal of their intervention meant they were not parties to the subsequent proceedings and judgment. Therefore, they were not barred from filing a separate action to protect their rights. The Court emphasized the principle that no man shall be affected by any proceeding to which he is a stranger. The filing of the reconveyance case was a necessary recourse after their intervention was dismissed, ensuring they were not deprived of property without due process. On whether the amendment of the decision in Civil Case No. 12887 is tantamount to annulment, and whether the reconveyance case is barred by prescription or laches: The Court ruled that the action for reconveyance based on an implied trust prescribes in ten years from the issuance of the Torrens title. In this case, the title was issued on September 28, 1990, and the complaint for reconveyance was filed on August 18, 1999, well within the ten-year period. Furthermore, the Court found that respondents were in possession of the subject property, as evidenced by the petitioner's own action for recovery of possession. Possession of the property renders an action for reconveyance imprescriptible, as it is akin to a suit for quieting of title. Therefore, the respondents were not guilty of laches, as their delay in filing the action was within the prescriptive period and they were in possession of the property, which provides a continuing right to seek judicial aid.
Main Doctrine
An action for reconveyance based on an implied or constructive trust prescribes in ten years from the issuance of the Torrens title over the property. If the plaintiff is in possession of the property, the action is imprescriptible and can be considered a suit for quieting of title.