GR 233055; (August, 2020) (Digest)
G.R. No. 233055, August 19, 2020
HEIRS OF PEDRO BERNARDO AND PACITA RONQUILLO, ET AL., PETITIONERS, VS. SPOUSES GUADALUPE M. GAMBOA AND TRINIDAD CABALLERO, RESPONDENTS.
FACTS
The petitioners are the heirs of spouses Pedro Bernardo and Pacita Ronquillo, holding title to Lot 1323-B (originally Lot 1323) under TCT No. NT-109773, derived from OCT No. P-2980. The respondents, spouses Guadalupe Gamboa and Trinidad Caballero, own and physically occupy the adjacent Lot 1324, acquired via a 1978 deed of sale. In 2003, a relocation survey initiated by the petitioners revealed that a 14,749-square-meter portion of Lot 1324, long possessed and cultivated by the respondents, was erroneously included within the technical description of the petitioners’ titled Lot 1323-B.
The respondents filed a complaint for cancellation of title and/or reconveyance, alleging that the petitioners’ predecessors-in-interest fraudulently procured a subdivision plan that vastly inflated the area of their original lot, leading to the unlawful inclusion of the disputed portion in their free patent application and subsequent title. The petitioners countered that the action was barred by res judicata, prescription, and laches, arguing their title had become indefeasible.
ISSUE
Whether the respondents are entitled to the reconveyance of the 14,749-square-meter portion of land erroneously included in the petitioners’ certificate of title.
RULING
Yes, the Supreme Court affirmed the grant of reconveyance. The legal logic rests on the principle that a Torrens title does not furnish a shield for fraud. While a certificate of title is indefeasible, it cannot be used to perpetuate an injustice against the true owner. The Court found that the respondents, through preponderant evidence including tax declarations and acts of possession since 1978, established their ownership of the disputed area. The petitioners’ title, derived from a free patent, was proven to have been secured through a fraudulent subdivision plan that incorporated land already occupied by another.
The action for reconveyance, based on implied or constructive trust, prescribes in ten years from the issuance of the title. However, the prescriptive period only begins to run from the date the plaintiff discovers the fraud. Here, the respondents discovered the wrongful inclusion only in November 2003 upon receiving the petitioners’ sketch plan and filed their complaint in December 2003. Thus, their action was timely filed. The defense of laches also fails, as the respondents promptly asserted their rights upon discovery. Consequently, the petitioners, as holders of a title tainted by fraud, are obligated to reconvey the property to its rightful owners, the respondents.