Purisima v. Purisima
REITERATIONFacts
The Antecedents: Respondents Macaria Purisima and Spouses Erlinda and Daniel Medrano filed a complaint for reconveyance, cancellation, and quieting of title against the heirs of Pascual Purisima Sr. (petitioners). Respondents alleged that Pascual Sr. owned Lot 71, PLS-631-D, and in 1960, sold portions thereof (Lot 71-A and Lot 71-B) to them to cover his medical bills. The sale was not recorded due to mutual trust. Respondents had been in open, continuous, and exclusive possession of their respective portions since the 1960s, paying realty taxes and having their own tenants. Petitioners, as heirs, executed an Extrajudicial Settlement of Estate of Deceased, Pascual Purisima and Sale in 1978, covering the entire Lot 71, including the portions sold to respondents. In 1991, Pascual Purisima Jr. was granted Free Patent No. 021528-91-2459 under the name "Heirs of Pascual Sr.", which was registered in 1992, leading to the issuance of Original Certificate of Title (OCT) No. P-5968 in favor of the "Heirs of Pascual Purisima Sr. rep. by Pascual Purisima Jr.". Respondents learned of the inclusion of their land in the extrajudicial settlement and OCT and repeatedly requested the surrender of the OCT for annotation, but petitioners ignored their pleas. Procedural History: The Regional Trial Court (RTC), Branch 11 of Tuao, Cagayan, dismissed the complaint for lack of written evidence of sale and held that even if a sale transpired, it was unenforceable due to the absence of a written document. The Court of Appeals (CA) reversed the RTC decision, finding that the 1978 Extrajudicial Settlement of Estate of Deceased, Pascual Purisima, Sr. and Sale confirmed the sale of the apportioned properties to respondents, and their signatures signified conformity. The CA held that the Statute of Frauds applies only to executory contracts, not to consummated ones, and that the 1960 sale was consummated. The CA further ruled that while the OCT was indefeasible, it did not create title and reconveyance was proper, especially since respondents were in possession, making the action imprescriptible. The Petition: Petitioners appealed to the Supreme Court, arguing that the CA erred in ruling that a sale occurred based on the 1978 document, which they claimed was a mere confirmation of a void 1960 sale. They also contended that the CA erred in allowing an attack on their indefeasible title.
Issue(s)
Whether the Court of Appeals erred in ruling that a sale of the subject properties occurred in 1960 and whether the Statute of Frauds is applicable to the alleged oral sale in 1960. Whether the action for reconveyance is proper despite the issuance of an Original Certificate of Title (OCT) in favor of the petitioners, considering the nature of the Torrens system and the possibility of implied trust. Whether the action for reconveyance is imprescriptible, considering the respondents' possession of the land. Whether the Court of Appeals erred in allowing an attack on the petitioners' indefeasible title, considering the principles of indefeasibility and the presence of fraud.
Ruling
The Petition for Review on Certiorari is DENIED. The September 23, 2011 Decision of the Court of Appeals in CA-G.R. CV No. 92001 is AFFIRMED.
Ratio Decidendi
On the existence of a sale and the applicability of the Statute of Frauds: The Supreme Court affirmed the Court of Appeals' finding that a valid consideration existed for the 1960 sale. The testimonies consistently showed that Pascual Sr. received monetary consideration for the apportioned lots, which was given due to his poor health. The Court reiterated that the Statute of Frauds applies only to executory contracts and not to those that have been totally or partially performed. The 1960 oral sale was deemed consummated, as evidenced by its express recognition in the 1978 Extrajudicial Settlement of Estate of Deceased, Pascual Purisima, Sr. and Sale, which was undisputed and acknowledged by the petitioners. The Court emphasized that a contract of sale, whether oral or written, is a consensual contract perfected by mere consent, requiring no particular form for its validity. Therefore, the 1960 oral sale stands, and its consequences are binding. On the propriety of reconveyance despite the OCT: The Court held that the transfer of ownership to the respondents arising from the 1960 sale effectively vested ownership in them from that time. The issuance of the OCT in favor of the petitioners, while indefeasible and binding, merely confirms or records an existing title and does not create or vest title. It cannot be used to protect a usurper or as a shield for fraud. The Court affirmed the CA's order for reconveyance, citing that the Torrens system is not designed to shield fraud or bad faith. The registered property is deemed held in trust for the real owners by the person in whose name it has been registered. On the imprescriptibility of the action for reconveyance: The Court clarified that an action for reconveyance based on an implied or constructive trust is the proper remedy for a party whose property was erroneously registered in another's name. The prescriptive period for reconveyance of registered property is ten years from the issuance of the certificate of title. However, this prescriptive period is not applicable when the complainant is in possession of the land to be reconveyed and the registered owner was never in possession. In such cases, the action for reconveyance filed by the possessor is in the nature of an action to quiet title, which is imprescriptible. Since the respondents were in possession of the property, their action for reconveyance was correctly deemed imprescriptible. On the attack on the petitioners' indefeasible title: The Court held that the Torrens system is not designed to shield fraud or bad faith. The registered property is deemed held in trust for the real owners by the person in whose name it has been registered. The issuance of the OCT in favor of the petitioners, while indefeasible and binding, merely confirms or records an existing title and does not create or vest title. It cannot be used to protect a usurper or as a shield for fraud.
Main Doctrine
An action for reconveyance of registered property based on an implied or constructive trust is the proper remedy of an aggrieved party whose property had been erroneously registered in another's name. The prescriptive period for reconveyance is ten years from the issuance of the certificate of title, but this does not apply if the complainant is in possession of the land, in which case the action is in the nature of an action to quiet title, which is imprescriptible.