Narvasa v. Imbornal
REITERATIONFacts
The Antecedents: Basilia Imbornal owned a property which she conveyed to her daughters Balbina, Alejandra, and Catalina. Catalina's husband, Ciriaco Abrio, applied for and was granted a homestead patent over an adjacent riparian land (Motherland), for which OCT No. 1462 was issued in his name. Ciriaco's heirs later obtained TCT No. 101495. Sometime in 1949, a First Accretion formed adjacent to the Motherland, and OCT No. P-318 was issued in the name of respondent Victoriano Imbornal. In 1971, a Second Accretion formed, and OCT No. 21481 was issued in the names of all respondents. Petitioners, as heirs of Francisco I. Narvasa, Sr. and Petra Imbornal (children of Alejandra and Balbina, respectively), claimed co-ownership over the Motherland and the accretions, alleging that Ciriaco used proceeds from the sale of the Sabangan property (inherited by the Imbornal sisters) to fund his homestead application, agreeing to hold the Motherland in trust for them. They also alleged that respondents fraudulently registered the accretions in their names despite not being the riparian owners. Procedural History: Petitioners filed an Amended Complaint for reconveyance, partition, and/or damages. The Regional Trial Court (RTC) ruled in favor of petitioners, finding an implied trust and ordering reconveyance of portions of the Motherland and accretions, along with damages. The Court of Appeals (CA) reversed the RTC, declaring Ciriaco's descendants as exclusive owners of the Motherland, Victoriano's descendants as exclusive owners of the First Accretion, and Pablo's descendants (respondents) as exclusive owners of the Second Accretion. The CA found that Ciriaco's title to the Motherland was indefeasible and that respondents acquired the accretions by prescription. The Petition: Petitioners' heirs seek review of the CA's Decision and Resolution, questioning the CA's findings on ownership of the Motherland and accretions, and raising the issues of prescription and the existence of an implied trust.
Issue(s)
Whether the Court of Appeals erred in declaring the descendants of Ciriaco Abrio as the exclusive owners of the Motherland. Whether the Court of Appeals erred in declaring the descendants of respondent Victoriano Imbornal as the exclusive owners of the First Accretion. Whether the Court of Appeals erred in declaring the descendants of Pablo Imbornal as the exclusive owners of the Second Accretion. Whether the action for reconveyance is barred by prescription. Whether an implied trust existed between the Imbornal sisters and Ciriaco Abrio with respect to the Motherland.
Ruling
The petition is bereft of merit. The Supreme Court affirmed the Decision and Resolution of the Court of Appeals, dismissing the Amended Complaint.
Ratio Decidendi
On Ownership of the Motherland: The Court found that the existence of an implied trust between the Imbornal sisters and Ciriaco Abrio with respect to the Motherland was not sufficiently established. Consequently, as the implied trust was not proven, petitioners failed to establish their ownership rights over the Motherland. The CA correctly held that Ciriaco and his heirs are the owners thereof, as Ciriaco acquired the homestead patent after undergoing the rigid process and satisfying the strict conditions set forth by law. The proceedings for land registration leading to the issuance of the title in Ciriaco's name are presumed regular and proper, a presumption not overcome by the evidence presented. On Ownership of the First Accretion: The Court reiterated that accretions automatically belong to the owners of the adjoining lands (riparian owners) by virtue of Article 457 of the Civil Code. However, the owner must register the accretions to prevent acquisition by prescription by third persons. Petitioners failed to prove they were the riparian owners of the Motherland to which the First Accretion attached, nor did they establish possession of either accretion. Respondents, armed with certificates of title and possession of the First Accretion, had superior claims. Therefore, petitioners' action for reconveyance with respect to the First Accretion must fail. On Ownership of the Second Accretion: The Court reiterated that accretions automatically belong to the owners of the adjoining lands (riparian owners) by virtue of Article 457 of the Civil Code. However, the owner must register the accretions to prevent acquisition by prescription by third persons. Petitioners failed to prove they were the riparian owners of the Motherland to which the Second Accretion attached, nor did they establish possession of either accretion. Respondents, armed with certificates of title and possession of the Second Accretion, had superior claims. Therefore, petitioners' action for reconveyance with respect to the Second Accretion must fail. While the action for reconveyance of the Second Accretion was filed within the prescriptive period, it failed on its substantive merits due to the lack of established implied trust and the superior claims of the respondents who possessed titles and actual possession of the accretions. On the Issue of Prescription: The Court held that the causes of action pertaining to the Motherland and the First Accretion are barred by prescription. An action for reconveyance based on an implied trust prescribes in ten (10) years from the date of registration of the deed or the issuance of the certificate of title, provided the plaintiff is not in possession. The Motherland's title was issued on December 5, 1933, making the action for reconveyance due by December 5, 1943. The First Accretion's title was issued on August 15, 1952, making the action due by August 15, 1962. The Amended Complaint was filed on February 27, 1984, which was beyond the prescriptive periods for both properties. Only the action for reconveyance of the Second Accretion was filed within the prescriptive period, which expired on November 10, 1988. On the Existence of an Implied Trust: The Court found that the existence of an implied trust between the Imbornal sisters and Ciriaco Abrio with respect to the Motherland was not sufficiently established. The burden of proving a trust rests on the party asserting it, requiring clear and satisfactory evidence. While oral evidence can be used, it must be trustworthy and not rest on loose or indefinite declarations. The Court found the oral testimony of petitioners' predecessors-in-interest insufficient, especially when weighed against the presumed regularity of the homestead patent award to Ciriaco under Commonwealth Act No. 141. There was a lack of evidence showing the Imbornal sisters' possession or assertion of rights over the Motherland during their lifetime, rendering Ciriaco's title indefeasible upon issuance of OCT No. 1462.
Main Doctrine
An action for reconveyance based on an implied trust prescribes in ten (10) years from the date of registration of the deed or the issuance of the certificate of title over the property, if the plaintiff is not in possession. Accretions automatically belong to the riparian owner, who must register the same to prevent acquisition by prescription by third persons.