G.R. No. L-15988; August 30, 1962
VICENTE GARCIA, BENJAMIN GARCIA, ANATALIA GARCIA, FABIAN GARCIA and TRANQUILINO REYES, plaintiffs-appellants, vs. PEDRO DE GUZMAN, defendant-appellee.

FACTS

The plaintiffs, heirs of Juan Garcia, filed an action in the Court of First Instance of Pangasinan to recover title to a parcel of land, cancel Original Certificate of Title No. 25381 in the name of the defendant Pedro de Guzman, and compel its reconveyance. They alleged that de Guzman secured the registration of the land in his name through fraud, relying on a deed of donation executed by their father, Juan Garcia, on June 1, 1918. The defendant moved to dismiss the complaint, arguing the action was barred by a prior judgment in Land Registration Case No. 765, which decreed registration in his favor on January 30, 1923, and by both extinctive and acquisitive prescription.
The trial court dismissed the complaint. It noted the decree of registration was entered in 1923 and the title issued thereafter. It found that Juan Garcia, from the execution of the deed in 1918 until his death in 1950, had 32 years to annul it on grounds of fraud but did not do so. Furthermore, during the cadastral survey in San Carlos in 1929, he had another opportunity to claim the property but failed to act. The court also held that the plaintiffs, after their father’s death, had sufficient time to file an action but brought suit beyond the prescriptive period.

ISSUE

Whether the trial court correctly dismissed the complaint on the grounds of res judicata and prescription.

RULING

Yes, the Supreme Court affirmed the dismissal. The legal logic rests on the indefeasibility of a Torrens title and the applicable prescriptive periods. The decree of registration in Land Registration Case No. 765, which became final in 1923, conclusively settled title in favor of de Guzman. An action to reopen a decree on the ground of fraud must be filed within one year from its entry, as per Section 38 of the Land Registration Act (Act No. 496). The plaintiffs’ action, filed in 1959, was filed decades beyond this absolute deadline.
Furthermore, the action for reconveyance based on an alleged fraudulent donation is barred by prescription. The Court agreed with the trial court that the alleged fraud constituted intrinsic fraud, giving rise to a constructive trust. An action based on such fraud prescribes in four years from its discovery. Juan Garcia had constructive notice of the registration proceedings and the subsequent cadastral survey in 1929. His failure to act for decades meant the right of action had long prescribed. Even assuming the land was not registered under the Torrens system, de Guzman would have acquired title by acquisitive prescription. The attached documents to the complaint, including the deed and the decree, indubitably established these defenses, making a full trial unnecessary. The dismissal was proper.