Heirs of Paclit v. Belisario
REITERATIONFacts
The Antecedents: Shomanay, Caturay, and Andres Paclit were the registered owners of a 75,824-square-meter parcel of land. On March 31, 1965, they executed a Deed of Sale with Real Estate Mortgage, selling the land to Cesar Belisario for P31,500.00 down, with the balance of P67,071.00 to be paid within six months. To secure this balance, Cesar mortgaged the land back to the sellers. Subsequently, on March 2, 1966, Cesar executed an Acknowledgement of Indebtedness, admitting a remaining balance of P36,820.00 and confirming the mortgage had been discharged, leading to the issuance of a new title in his name. Procedural History: On August 13, 2003, the heirs of the original sellers (petitioners) filed a Complaint against Cesar and Salud Belisario (respondents) for reconveyance and annulment of the deed of sale and titles, alleging non-payment of the purchase price balance and fraud in the mortgage cancellation. They claimed to have discovered the sale and title cancellation only in July 1999, 33 years later. The respondents moved to dismiss for non-payment of docket fees. The Regional Trial Court (RTC) dismissed the complaint on May 7, 2004, citing prescription, as the action was filed 38 years after the deed of sale. The Court of Appeals (CA) affirmed this dismissal on December 19, 2008, also finding the claim barred by laches due to 38 years of inaction. The CA denied the petitioners' motion for reconsideration on August 26, 2009, noting it was filed out of time. The Petition: The petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in affirming the RTC's dismissal of their complaint on the ground of prescription. They contended that the defense of prescription was not properly raised. The respondents argued the petition should be denied because the CA's decision had already become final due to the petitioners' failure to file their motion for reconsideration within the reglementary period. The Supreme Court denied the petition, holding that the CA's decision had become final and executory due to the petitioners' belated motion for reconsideration, and further noting that even if the timeliness issue were disregarded, the CA did not commit reversible error as the action was indeed barred by prescription, which the court can raise motu proprio when evident from the record.
Issue(s)
Whether the Court of Appeals erred in affirming the dismissal of the complaint on the ground of prescription. Whether the Court of Appeals erred in ruling that the motion for reconsideration was filed out of time. Whether the RTC could motu proprio dismiss the case on the ground of prescription even if the defense was not raised in the motion to dismiss.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the prescription of the action: The action filed by the petitioners was essentially one for rescission (resolution) under Article 1191 of the Civil Code, seeking to annul the deed of sale due to alleged non-payment of the purchase price. Actions based on a written contract, including rescission under Article 1191, prescribe in 10 years from the time the right of action accrues, as provided by Article 1144 of the Civil Code. The deed of sale was executed on March 31, 1965, with a six-month period for payment of the balance, meaning the right of action accrued in September 1965. The complaint was filed on August 13, 2003, approximately 38 years later. This clearly falls outside the 10-year prescriptive period, making the claim time-barred. The principle of prescription, as a statute of repose, prevents stale claims from arising after a long period. On the timeliness of the motion for reconsideration and the finality of the CA Decision: The Rules of Court grant a party 15 days from receipt of a CA decision or order to appeal or move for reconsideration. After this period lapses, the decision becomes final and executory. The CA correctly pointed out that petitioners received the decision on January 5, 2009, as evidenced by the Registry Return Receipt, not February 28, 2009, as claimed. Therefore, their motion for reconsideration filed on March 11, 2009, was 65 days late. Once a judgment attains finality, it becomes immutable and unalterable, except under extraordinary circumstances, which are not present here. The attempt to conceal the actual receipt date by alleging a later date further undermines their position. On the RTC's authority to dismiss motu proprio on prescription: The RTC did not err in dismissing the case on the ground of prescription, even though the respondents did not raise this defense in their motion to dismiss. Section 1, Rule 9 of the Rules of Court allows courts to dismiss a claim motu proprio when it appears from the pleadings or evidence on record that the action is barred by the statute of limitations. This is consistent with jurisprudence, such as Feliciario v. Canoza, which emphasizes that courts have the authority and discretion to dismiss an action on the ground of prescription if the facts demonstrating the lapse of the prescriptive period are sufficiently apparent on the record, even if the defense has not been asserted at all.
Main Doctrine
A judgment that has attained finality becomes immutable and unalterable, and cannot be modified even by the highest court, except under extraordinary circumstances. Furthermore, courts may motu proprio dismiss a claim barred by prescription if the facts demonstrating the lapse of the prescriptive period are apparent from the pleadings or evidence on record, even if the defense was not raised by the defendant.