G.R. No. 119714 May 29, 1997
SALVADOR S. ESQUIVIAS and ALICIA DOMALAON-ESQUIVIAS, petitioners, vs. COURT OF APPEALS, JOSE G. DOMALAON, ELENA G. DOMALAON and REGISTER OF DEEDS OF SORSOGON, respondents.

FACTS

Julia Galpo de Domalaon owned a 1,260-square meter lot with a house, which she constituted as a family home in 1950, naming her children, including petitioners Alicia and respondents Jose and Elena, as beneficiaries. In 1974, Julia executed a Deed of Absolute Sale in favor of her son-in-law, petitioner Atty. Salvador Esquivias, covering the house and a specific portion of the lot. In 1977, after dissolving the family home, Julia executed another deed selling the entire 1,260-square meter property to her son, respondent Jose. Subsequently, Jose and his sister Elena succeeded in obtaining free patents and original certificates of title for the larger 6,270-square meter parcel encompassing the original lot. Petitioners filed an action for reconveyance and damages, claiming ownership over the entire property based on an alleged promise by Julia’s late husband. The trial court ruled partially in favor of petitioners, ordering reconveyance of the specific portion described in the 1974 deed. The Court of Appeals reversed, dismissing the complaint.

ISSUE

Whether petitioners are entitled to reconveyance of the property covered by the 1974 Deed of Absolute Sale, despite the subsequent issuance of free patent titles to respondents.

RULING

Yes, the Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision. The Court held that the 1974 sale to Atty. Esquivias was valid. The prior disbarment case against him, which alleged fraud, had been dismissed by the Court for lack of merit, adopting the Solicitor General’s finding that the deed was genuine and no misrepresentation occurred. This finding is binding under the doctrine of conclusiveness of judgment. Consequently, petitioners acquired ownership of the specific portion described in the 1974 deed upon its execution. The subsequent dissolution of the family home in 1977 did not invalidate this prior consummated sale. The titles obtained by respondents through free patent, while generally incontrovertible, do not override the vested rights of petitioners arising from the earlier sale. Since respondents’ titles were acquired when petitioners’ ownership already existed, and there was no showing the property was transferred to innocent purchasers for value, respondents hold the title in trust for petitioners over that specific portion. An action for reconveyance is precisely the proper remedy to compel the transfer of the property wrongfully registered in another’s name to its rightful owner, without challenging the certificate of title itself.