G.R. No. 189418 , June 20, 2012
HEIRS OF SHOMANAY PACLIT, ET AL. VS. CESAR BELISARIO AND SALUD BELISARIO

FACTS

The petitioners are the heirs of Shomanay, Caturay, and Andres Paclit, the original registered owners of a parcel of land in Benguet. On March 31, 1965, the Paclits sold the land to respondent Cesar Belisario via a Deed of Sale with Real Estate Mortgage, acknowledging receipt of a downpayment. The balance was secured by a mortgage on the property in favor of the vendors. By March 2, 1966, Cesar executed an Acknowledgment of Indebtedness, admitting an unpaid balance but stating the mortgage had been discharged. Consequently, the original title was cancelled, and a new one was issued in Cesar’s name in 1965.
On August 13, 2003, the heirs filed a Complaint for reconveyance and annulment of the deed and titles against the respondents. They alleged that the balance of the purchase price remained unpaid and that the mortgage cancellation was fraudulent. They claimed they only discovered the sale and title cancellation in July 1999. The Regional Trial Court (RTC) dismissed the complaint on the ground of prescription, a ruling affirmed by the Court of Appeals (CA). The CA also noted the petitioners’ motion for reconsideration was filed beyond the reglementary period, rendering its decision final.

ISSUE

Whether the complaint for reconveyance and annulment was correctly dismissed on the ground of prescription.

RULING

Yes, the petition is denied. The Supreme Court affirmed the dismissal. The action had prescribed, and the CA decision had become final and executory.
On procedural finality, the Court found the petitioners failed to timely move for reconsideration of the CA Decision. Registry records showed counsel received notice on January 5, 2009, but the motion was filed only on March 12, 2009, far beyond the 15-day reglementary period. Consequently, the CA Decision attained finality and was no longer subject to review.
On the substantive issue of prescription, the Court upheld the lower courts. The cause of action, whether framed as an action for annulment of a written contract or for rescission based on non-payment, accrued from the execution of the deed in 1965 and the issuance of the new title in Cesar’s name the same year. Under Article 1144 of the Civil Code, an action upon a written contract must be brought within ten years. The complaint filed in 2003, nearly four decades later, was indisputably barred by prescription. The Court emphasized that prescription serves as a statute of repose to suppress stale claims arising after great distances of time, when facts have become obscure. The petitioners’ prolonged inaction for 38 years before assailing the title constituted laches.