GR 221513; (December, 2016) (Digest)
G.R. No. 221513. December 05, 2016
SPOUSES LUISITO PONTIGON AND LEODEGARIA SANCHEZ-PONTIGON, PETITIONERS V. HEIRS OF MELITON SANCHEZ, NAMELY: APOLONIA SANCHEZ, ET AL., REPRESENTED BY TERESITA SANCHEZ MANALANSAN, RESPONDENTS.
FACTS
Meliton Sanchez owned a 24-hectare parcel of land registered under OCT No. 207. Upon his death in 1948, the property passed to his three children: Apolonio, Flaviana, and Juan Sanchez. Respondents are the heirs of Flaviana, while petitioner Leodegaria is the daughter of Juan. In 2000, respondents discovered that the original title was missing from the Register of Deeds, and that petitioners had obtained TCT No. 162403-R in their names in 1980 without any apparent deed of conveyance. They filed a complaint to declare the title null and void, alleging fraud and that petitioners held the property in trust for all heirs.
Petitioners defended their title by presenting an Extrajudicial Settlement with Absolute Sale dated 1979, allegedly executed by the three heirs, and a 1979 Decision from the Court of First Instance approving the partition. They argued the action was barred by prescription and that respondents had no cause of action. The trial court declared petitioners’ title null and void due to fraud and irregularities, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the nullification of TCT No. 162403-R and in ruling that respondents’ action had not prescribed.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The legal logic centered on the indefeasibility of a torrens title and the imprescriptible nature of an action to declare it void ab initio due to fraud. A title originating from a void deed is itself void, and the defense of prescription cannot be invoked. The Court found the purported Extrajudicial Settlement and the CFI Decision approving it to be spurious. The respondents, as co-owners, presented overwhelming evidence, including testimony from the Register of Deeds, that the owner’s duplicate of OCT No. 207 was never cancelled and bore no annotations, conclusively proving that the derivative title was fraudulently secured.
The action had not prescribed because an action to declare a void title a nullity does not prescribe. Prescription does not run against a co-owner or heir for the purpose of demanding reconveyance of property held in trust by another, as petitioners were deemed trustees of the property for the benefit of all heirs. The fraudulent issuance of the title rendered it void from the beginning, making the defense of acquisitive prescription unavailable. The Court upheld the finding of fraud, which vitiated the petitioners’ claim of ownership and justified the reinstatement of the original certificate of title in the name of the deceased Meliton Sanchez.