G.R. No. 205680 , November 21, 2018
HEIRS OF CIRIACO BAYOG-ANG, NAMELY: CELERINO VALLE AND PRIMITIVO VALLE, PETITIONERS, VS. FLORENCE QUINONES, JOINTLY WITH HER HUSBAND, JEREMIAS DONASCO, AS SUBSTITUTED BY THEIR SURVIVING CHILDREN, NAMELY: JEANY FLOR Q. DONASCO, ROYCE Q. DONASCO, AND WILMER Q. DONASCO, RESPONDENTS.

FACTS

The case involves conflicting claims over a parcel of land originally owned by Ciriaco Bayog-Ang. Respondents, Florence Quinones and her husband, claimed ownership by virtue of a Deed of Absolute Sale executed by Bayog-Ang in 1964. However, they never registered the sale or secured a transfer certificate of title. After Bayog-Ang’s death, his heirs, the petitioners, executed an Extrajudicial Settlement of his estate in 1996, adjudicating the entire property, including the disputed portion, to themselves. They subsequently obtained a new Transfer Certificate of Title (TCT) in their names in 1997. Upon discovering this, respondents filed an action for Specific Performance and Damages in 1998, seeking to nullify the settlement and compel the segregation and transfer of the land they purchased.
Petitioners argued the action was barred by prescription, contending it was based on a written contract with a ten-year prescriptive period from 1964. The Regional Trial Court (RTC) dismissed the complaint, applying the rule on double sales under Article 1544 of the Civil Code. It ruled that petitioners, as the first registrants in good faith, acquired a superior right over the land. The Court of Appeals (CA) reversed the RTC, finding no double sale occurred and that the action had not prescribed.

ISSUE

The core issue is whether the action for specific performance filed by the respondents had already prescribed.

RULING

The Supreme Court denied the petition and affirmed the CA decision, holding that the action had not prescribed. The Court clarified that the applicable prescriptive period is ten years from the accrual of the cause of action, not from the execution of the deed. A cause of action accrues when the act violating a right occurs. In this case, the violation of respondents’ right occurred only when petitioners, as heirs, repudiated the sale by adjudicating the property to themselves in 1996 and obtaining a new title in 1997. The respondents’ right to demand performance from the vendor’s heirs arose only upon this act of repudiation. Consequently, the filing of the complaint in 1998 was well within the ten-year prescriptive period.
The Court further ruled that the rule on double sales under Article 1544 was inapplicable. That provision governs a situation where a single vendor sells the same property to two different buyers. Here, there was only one sale—from Bayog-Ang to the respondents. The subsequent issuance of title to the petitioners was not based on a second sale but on an extrajudicial settlement as heirs. The petitioners merely stepped into the shoes of their predecessor-in-interest, Bayog-Ang, and were thus bound by the sale he executed. Their title, being derived from him, was subject to the existing unregistered sale in favor of the respondents.