GR 169898; (June, 2007) (Digest)
G.R. No. 169898, June 8, 2007
Spouses Anita and Honorio Aguirre, Petitioners, vs. Heirs of Lucas Villanueva, Respondents.
FACTS
The petitioners, Spouses Aguirre, were awarded a 140-square-meter lot by the Supreme Court in a prior decision, having acquired it through acquisitive prescription. The Court also ruled that the respondents’ action for reconveyance was barred by laches, as it was filed 16 years after the relevant events. The respondents filed a motion for reconsideration, arguing that the petitioners could not be considered possessors in good faith and with just title. They contended that any acquisitive prescription should be extraordinary, requiring 30 years of adverse possession. They further asserted that the Court erred in finding their action for annulment of the deed of exchange and recovery of ownership was barred by laches.
ISSUE
Whether the respondents’ action for reconveyance is barred by prescription and whether the petitioners have acquired ownership over the disputed property.
RULING
The motion for reconsideration is denied. First, the action for reconveyance is barred by extinctive prescription. An action for reconveyance based on an implied trust arising from fraud prescribes in ten years. The prescriptive period commences from the date of registration of the fraudulent deed. Here, the Deed of Exchange was registered on June 13, 1973. The complaint filed in 1999 is far beyond the ten-year period. Even if the period is reckoned from 1981, when respondents allegedly became aware of petitioners’ acts of possession, the 1999 filing remains time-barred. This rule applies because respondents were not in possession of the property; had they been in possession, the action could be considered imprescriptible as one for quieting of title.
Second, respondents failed to prove ownership through possession. Their evidence of ownership was limited to gathering produce from two trees and an unsubstantiated claim that their predecessor permitted another to occupy the land. This was insufficient to establish possession in the concept of an owner. Conversely, petitioners possessed the lot for 26 years, from 1971. While the Court noted petitioners may not have been in good faith due to a lack of diligent inquiry into the property’s history, equity favors awarding the property to them given their lengthy, uninterrupted possession compared to the respondents’ weak claim of ownership. Thus, the denial of the motion for reconsideration is final.