G.R. No. 33166 May 29, 1989
A.D. GUERRERO, PHILIPPINE NATIONAL BANK and SHERIFF OF QUEZON CITY, petitioners, vs. MERCEDES P. JUNTILLA and COURT OF APPEALS, respondents.

FACTS

The case originated from a 1957 judgment against Alipio Juntilla and a corporation. To satisfy the debt, a property registered under Alipio’s name, with a notation of his marriage to Mercedes Juntilla, was levied upon and sold at public auction in 1958 to the Philippine National Bank (PNB). The court subsequently ordered the cancellation of the original title and the issuance of a new one in PNB’s name, with possession delivered in 1968. PNB later sold the property to A.D. Guerrero. In June 1968, Mercedes Juntilla filed a complaint seeking to nullify the sale and recover possession. She alleged the debt was corporate, not conjugal, and thus her alleged one-half conjugal share in the property could not be levied upon. She further claimed sole ownership by virtue of a prior Juvenile Court judgment dissolving the conjugal partnership. The petitioners moved to dismiss the complaint.

ISSUE

The primary issue is whether the trial court correctly denied the motion to dismiss, thereby allowing Mercedes Juntilla’s action to proceed, or whether her claim is barred by prescription and her failure to state a cause of action.

RULING

The Supreme Court granted the petition and ordered the dismissal of the complaint. The Court held that Mercedes Juntilla’s action had prescribed. The property was sold at public auction in 1958, and the certificate of sale was registered in 1959. Her cause of action, if any, accrued at that time. By filing her complaint only in 1968, nearly a decade later, she exceeded the prescriptive period for annulment of a sale, which is four years from discovery of the defect, or the ten-year period for reconveyance based on an implied trust. Furthermore, the Court ruled she failed to state a cause of action. She did not sufficiently allege that the property was conjugal. Registration solely in the husband’s name creates a presumption that it is his exclusive property. This presumption was not overcome by mere allegations, especially absent any claim that the property was acquired during the marriage. The prior Juvenile Court case, which allegedly declared her sole owner, was not properly pleaded with its judgment presented. Finally, the rights of an innocent purchaser for value, A.D. Guerrero, were invoked. As a transferee of registered land, Guerrero could rely on the correctness of PNB’s Torrens title without obligation to investigate beyond it. The Court emphasized the principle of indefeasibility of title, protecting buyers who rely on the face of the certificate.