G.R. No. 85240 ; July 12, 1991
HEIRS OF CECILIO CLAUDEL, petitioners, vs. HON. COURT OF APPEALS, HEIRS OF MACARIO, ESPERIDIONA, RAYMUNDA and CELESTINA CLAUDEL, respondents.

FACTS

Cecilio (Basilio) Claudel acquired Lot No. 1230 from the Bureau of Lands in 1922, securing TCT No. 7471 in 1923. Upon his death in 1937, the property passed to his heirs (petitioners), who partitioned it in 1972 and obtained separate titles. In 1976, the heirs of Cecilio’s siblings (private respondents) filed a complaint for cancellation of titles and reconveyance. They alleged that in 1930, their parents had verbally purchased portions of the lot from Cecilio for P30.00, presenting a 1930 subdivision plan as their sole evidence of the sale.
The Court of First Instance (CFI) dismissed the complaint. It found the action was not prosecuted in the name of all real parties-in-interest, noted the absence of any document evidencing the sale of real property, and held that the action, filed over 30 years after the alleged 1930 sale, had prescribed. The Court of Appeals reversed, holding that the Statute of Frauds did not apply to a consummated sale, that oral evidence was admissible, and that the subdivision plan sufficiently evidenced the transaction.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s dismissal of the complaint for reconveyance based on a verbal sale of land.

RULING

Yes, the Supreme Court reversed the Court of Appeals and reinstated the CFI decision. The legal logic rests on the primacy of the trial court’s factual findings and the application of substantive law on prescription and evidence. The CFI correctly found the action barred by prescription. An action for reconveyance based on an implied or constructive trust prescribes in ten years from the issuance of the title, which operates as a constructive notice. Here, the original title was issued in 1923. The action filed in 1976 was filed decades beyond the prescriptive period.
Furthermore, the private respondents failed to prove the alleged verbal sale by clear and convincing evidence. The lone subdivision plan was insufficient to establish the fact of sale, its terms, or the identities of the specific buyers. While the Statute of Frauds may not apply to a fully executed oral sale, the proponents of such a sale still bear the burden of proving its existence. The trial court, which is in the best position to assess evidence, found this proof lacking. The appellate court provided no cogent reason to overturn these factual conclusions. Therefore, the petitioners’ Torrens titles, acquired from their father’s original valid title, must prevail.