JUAN ENDOZO and SPOUSES JOSE and DOROTHY NGO, Petitioners, vs. THE HEIRS of JULIA BUCK, Respondents.
FACTS
Petitioner Juan Endozo claimed ownership over a parcel of land identified as Lot 4863, Cad. 355 in Tagaytay, asserting it was part of a 16-hectare family property partitioned among his parents’ heirs. He subsequently sold the lot to co-petitioners, spouses Jose and Dorothy Ngo. However, they discovered that respondent Julia Buck had already obtained a Free Patent and an Original Certificate of Title (OCT No. 0-602) for the same lot in 1982. Endozo and the Ngos filed an action for reconveyance with damages against Buck, arguing their superior claim.
The Regional Trial Court (RTC) dismissed the complaint, ruling that Buck had a better right based on her Torrens title. The court found Endozo’s evidence, consisting mainly of tax declarations for properties in Talisay, Batangas, insufficient to overcome Buck’s registered title. It also noted Endozo’s failure to present the alleged extrajudicial partition document. The Court of Appeals affirmed the RTC decision with modification, deleting the awards for moral damages and attorney’s fees.
ISSUE
The core issue is whether the petitioners have a superior right to the disputed property, warranting the reconveyance of Lot 4863 from the heirs of Julia Buck.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court emphasized that the principal issue was factual-specifically, the identity and location of the contested lot. The trial court found, and the CA affirmed, that the land claimed by the petitioners was not the same Lot 4863 covered by Buck’s title. The petitioners’ evidence pertained to properties situated in Talisay, Batangas, not the land in Tagaytay City registered under Buck’s name. Factual findings of the trial court, especially when affirmed by the CA, are binding on the Supreme Court.
On the legal aspects, the Court held that an action for reconveyance based on an implied or constructive trust prescribes in four years from the issuance of the title. Since Buck’s OCT was issued in 1982 and the complaint was filed only in 1991, the action had already prescribed. Furthermore, the petitioners’ motion for a new trial, based on a new claim that the lot was classified as forest land, was correctly denied. Such a classification, even if true, would not bolster the petitioners’ claim for ownership but would instead mean the land is inalienable and should revert to the State, a claim they have no standing to assert. The Court also found no merit in the allegation that the trial court merely adopted the respondent’s draft decision, as the record showed both parties submitted draft decisions and the court’s final ruling contained its own independent analysis.
