Pama v. Pama
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and proceeds of a homestead, Lot No. 463, originally applied for by Matea Panes. Following her death, her son Guillermo Pama took possession and eventually secured title. The petitioners, heirs of Matea Panes' other children (Godofredo and Julieta), claim a share in the homestead or its proceeds, asserting that the homestead was intended for all the children. Guillermo Pama, however, contends that the homestead was his and that he is entitled to all proceeds from its sale. 2. Procedural History: The petitioners, Rosario Celo Vda. de Pama and Victoria Jorda, filed a complaint for reconveyance of real property against Guillermo Pama and Lourdes Pagayan in the Court of First Instance of Cotabato, Civil Case No. 170. The trial court dismissed their complaint on the ground of prescription. The petitioners then elevated the matter to the Court of Appeals, which affirmed the dismissal. This resolution addresses the petition for review on certiorari of the appellate court's decision. 3. The Petition: The petitioners seek review on certiorari of the decision of the defunct Court of First Instance of Cotabato. They argue that the dismissal of their complaint for reconveyance was erroneous. The Supreme Court, however, acting on the petition, found that Guillermo Pama's registration of an affidavit of adjudication on June 18, 1956, asserting sole heirship and obtaining title in his name, constituted an adverse claim. As the petitioners filed their complaint on April 28, 1969, more than ten years after the cause of action accrued, the Court found the action to have prescribed and thus dismissed the petition.
Issue(s)
Whether the action for reconveyance has prescribed. Whether the registration of the affidavit of adjudication and the subsequent title constituted adverse title and constructive notice to the petitioners.
Ruling
The petition for review on certiorari was dismissed, and the questioned order dismissing the petitioners' complaint in Civil Case No. 170 was affirmed. No costs were awarded.
Ratio Decidendi
On Whether the action for reconveyance has prescribed: The Court reiterated the settled doctrine that an action for reconveyance of real property based upon constructive or implied trust prescribes in ten (10) years. This period is counted from the date adverse title is asserted by the possessor of the property. The Court cited established jurisprudence in support of this principle, emphasizing the finality of such actions after the lapse of the prescriptive period. The Court found that the registration of the affidavit of adjudication on June 18, 1956, constituted the assertion of adverse title. The petitioners filed their complaint for reconveyance only on April 28, 1969, which was twelve (12) years, ten (10) months, and ten (10) days after their cause of action had accrued. Therefore, the action had clearly prescribed. On Whether the registration of the affidavit of adjudication and the subsequent title constituted adverse title and constructive notice to the petitioners: The Court held that when respondent Guillermo Pama caused the registration of the affidavit of adjudication on June 18, 1956, declaring himself the sole heir of the late Matea Pama and obtained Transfer Certificate of Title No. T-4006 in his own name, he thereby excluded petitioners from the estate of the deceased Matea Pama. Consequently, this act constituted the assertion of a title adverse to them. Such registration serves as constructive notice to the petitioners of the respondent's adverse claim to the property. The Court relied on established jurisprudence that registration of an instrument in the Property Registration Decree constitutes constructive notice to the whole world. This constructive notice is deemed to have been served from the date of registration, triggering the commencement of the prescriptive period.
Main Doctrine
An action for reconveyance of real property based upon constructive or implied trust prescribes in ten (10) years, counted from the date adverse title is asserted by the possessor of the property. The registration of an affidavit of adjudication declaring oneself the sole heir and obtaining a title in one's name constitutes constructive notice of an adverse claim.