G.R. No. 236173 , April 11, 2023
HEIRS OF NICANOR GARCIA, AS REPRESENTED BY SPOUSES JOSEFINA GARCIA-DOBLADA AND JOSE V. DOBLADA, PETITIONERS, VS. SPOUSES DOMINADOR J. BURGOS AND PRIMITIVA I. BURGOS, SPOUSES FILIP GERARD V. BURGOS AND MARITES A. BURGOS, AND ESTER GABRIEL DOMINGUEZ, RESPONDENTS.

FACTS

The petitioners, Heirs of Nicanor Garcia, filed a Complaint for Reconveyance of Ownership, Possession and Property, Breach of Agreement/Undertaking, Cancellation of Titles, Nullity of Deeds of Sale, and Damages before the RTC of Malolos, Bulacan. They alleged that their predecessor, Nicanor Garcia, was the legitimate tenant or kasama of an 8,115-sq.m. parcel of land owned by Fermina Francia under a Kasunduan. After Nicanor’s death, they discovered that respondent Dominador Burgos, who was Nicanor’s farm worker, had through fraudulent means caused the transfer of a 2,705-sq.m. portion of the land to himself, subdivided it, and registered the lots under his name and the names of other respondents. An Undertaking was executed before the barangay where Dominador agreed to reconvey the lots not yet transferred to third parties, but he failed to comply. The RTC initially found no merit in the affirmative defenses raised by Dominador (lack of jurisdiction over an agrarian dispute, lack of cause of action, and lack of a barangay certification). However, upon motion for reconsideration, the RTC dismissed the Complaint, ruling that the Heirs had no cause of action because Nicanor was merely a tenant and not the owner, and thus could not seek reconveyance; that the Kasunduan was unnotarized and not binding; that the action had prescribed (filed in 2016, titles issued in 1999); and that breach of the barangay Undertaking was cognizable by a lower court. The Heirs filed a Petition for Review on Certiorari with the Supreme Court, which was denied, as was their first motion for reconsideration. They then filed a Second Motion for Reconsideration.

ISSUE

Whether the Regional Trial Court correctly dismissed the Complaint for Reconveyance on the grounds of lack of cause of action and prescription.

RULING

No. The Supreme Court granted the Second Motion for Reconsideration, set aside its previous rulings, and directed the RTC to conduct further proceedings. The Court held that an agricultural lessee has the legal personality to file an action for reconveyance. The right of an agricultural lessee is a real right that attaches to the landholding, enforceable against the landowner and any transferee. The action for reconveyance based on an implied or constructive trust prescribes in ten years from the issuance of the title, but the prescriptive period does not run against one in actual possession of the land. Since the Heirs, as successors of the tenant, alleged they were in actual possession, the issue of prescription involves a question of fact that must be resolved in a full-blown trial. The RTC erred in dismissing the case at a preliminary stage based solely on the allegations in the Complaint and its annexes. The case must be remanded for trial to allow the Heirs to prove their allegations of tenancy rights, possession, and the implied trust created by Dominador’s alleged fraudulent registration.