Crisostomo v. Garcia
REITERATIONFacts
The Antecedents: Respondent Florito M. Garcia, Jr. filed a civil case for cancellation of Transfer Certificate of Title (TCT) No. 273165 and reconveyance against petitioners-spouses Marlene and Jose Crisostomo. Respondent alleged that on September 24, 1986, Victoria Garcia Vda. de Crisostomo, mother of petitioner Jose G. Crisostomo, sold the property to him via a Deed of Absolute Sale, with petitioners Jose Crisostomo and his sister Cristina Crisostomo signing as witnesses. Respondent allowed Victoria and her children to stay as lessees and transferred the tax declaration to his name. However, petitioners allegedly secured a loan from the National Home Mortgage Finance Corporation using the property as security through bad faith and machinations, and subsequently transferred the property to their names, obtaining TCT No. 273165, without respondent's knowledge and consent. Procedural History: Petitioners filed an Urgent Motion to Dismiss, arguing that the cause of action, based on the 1986 Deed of Sale, had prescribed as it was filed beyond the 10-year prescriptive period under Article 1144 of the Civil Code (filed June 20, 2002, more than 16 years after September 24, 1986). Respondent countered that the action was for cancellation of title and reconveyance based on an implied or constructive trust, not specific performance, and thus the 10-year period should be counted from the assertion of adverse title. The Regional Trial Court (RTC) denied the motion to dismiss, finding that the action was for cancellation of title based on fraud discovered in 1993, and thus had not prescribed, directing petitioners to file an Answer. Petitioners' motion for reconsideration was denied. They then filed a Petition for Certiorari before the Court of Appeals (CA), arguing grave abuse of discretion. The CA dismissed the petition outright, stating that prescription is a question of fact not proper in a certiorari petition. Petitioners' motion for reconsideration was denied. The Petition: Hence, the present petition before the Supreme Court. Petitioners question whether the CA erred in ruling that prescription is a question of fact, in refusing to resolve the merits of the case below, and whether the respondent's action had already prescribed.
Issue(s)
Whether the Court of Appeals erred in ruling that the issue of prescription involves a question of fact. Whether the Court of Appeals erred by refusing to resolve the merits of the petition below, assuming prescription involves a question of fact. Whether the action filed by the respondent had already prescribed.
Ruling
The Supreme Court granted the petition in part, agreeing that the Court of Appeals should have resolved the petition on the merits. However, it denied the prayer for dismissal of the civil case. The case was remanded to the RTC for further proceedings.
Ratio Decidendi
On the issue of whether prescription is a question of fact or law: The Court reiterated the distinction: a question of fact arises from doubt as to the truth or falsehood of alleged facts, requiring examination of probative value of evidence. A question of law exists when there is doubt as to the law itself on a given set of facts, resolvable solely by legal provisions. The Court noted that while prescription is generally a factual matter, it can be a question of law if the facts are admitted or undisputed, allowing for resolution without reviewing evidence. In this case, the facts necessary to determine prescription were extant from the records, making it reviewable for grave abuse of discretion by the CA. The Court found that the CA erred in dismissing the petition outright on the ground that prescription is purely a question of fact, as the issue of grave abuse of discretion by the trial court in denying the motion to dismiss was reviewable. On whether the Court of Appeals erred by refusing to resolve the merits: The Court agreed that the CA should have resolved the merits, especially considering the potential for grave abuse of discretion by the trial court. While certiorari is not meant to correct every interlocutory ruling, it is appropriate to correct grave abuse of discretion or a whimsical exercise of judgment that amounts to lack or excess of jurisdiction. The CA could have determined if the trial court abused its discretion by ruling that the action had not prescribed, given the facts available in the records. However, to avoid further cost and delay, the Supreme Court opted to resolve the issue of prescription itself. On whether the action filed by the respondent had already prescribed: The Court clarified that the petitioners' reliance on the four-year prescriptive period for voidable contracts under Article 1391 of the Civil Code was misplaced. The respondent's action for reconveyance and cancellation of title was based on an implied or constructive trust under Article 1456 of the Civil Code, arising from the alleged fraud by which petitioners obtained the title. The Court held that an action for reconveyance based on an implied or constructive trust prescribes in ten (10) years from the issuance of the title or from the date of the fraudulent registration, pursuant to Article 1144 of the Civil Code. The Deed of Sale was dated September 24, 1986, and the title was registered in petitioners' names on November 16, 1993. The complaint was filed on June 20, 2002. Counting ten years from the registration of the title (November 16, 1993), the prescriptive period would end on November 16, 2003. Since the complaint was filed on June 20, 2002, it was filed within the ten-year prescriptive period. Therefore, the action had not prescribed.
Main Doctrine
An action for reconveyance based on an implied or constructive trust, arising from property acquired through fraud, prescribes in ten (10) years from the registration of the title, pursuant to Article 1144 of the Civil Code.