G.R. No. L-55222 March 14, 1988
LILIA CANETE, ET AL., plaintiffs-appellants, vs. GABRIEL BENEDICTO, defendant-appellee.

FACTS

The plaintiffs, heirs of spouses Tomas Canete and Teodora Jison, filed a complaint on June 13, 1974, seeking to annul the Torrens title of Gabriel Benedicto over Lot No. 757, a 28-hectare parcel in Negros Occidental. They alleged the lot was originally registered in the names of the Canete spouses in 1919, who possessed it until the war. After the war, Benedicto unlawfully occupied and cultivated it. The plaintiffs claimed Benedicto surreptitiously obtained a judicial reconstitution of the Torrens title, securing TCT No. RT-13164 in his name. They prayed for cancellation of his title, reissuance of the original title in their predecessors’ names, accounting of fruits, delivery of possession, and attorney’s fees.
Benedicto moved to dismiss the complaint on several grounds, including prescription. The trial court ordered him to submit documents proving prescription. Benedicto complied, presenting his reconstituted title issued in 1964, tax declarations in his name dating back to 1925, and documents showing a series of transactions culminating in a 1963 Deed of Absolute Sale from the Philippine National Bank to him. The plaintiffs were furnished copies but did not file an opposition or appear at the hearing.

ISSUE

Whether the trial court correctly dismissed the complaint on the ground of prescription.

RULING

Yes, the Supreme Court affirmed the dismissal. The trial court properly directed the submission of documentary evidence, which remained uncontroverted. The plaintiffs had ample opportunity to challenge the authenticity of Benedicto’s documents but failed to do so in their comments or at the hearing. The evidence established that Benedicto’s title, TCT No. RT-13164, was a reconstitution of a prior title (TCT No. 4169) issued in his name, implying the original certificate (OCT No. 12969) in the Canetes’ names had been cancelled long before. Tax declarations from as early as 1926 consistently named Benedicto as the owner.
The Court emphasized that 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. The reconstituted title was issued on July 13, 1964, but the complaint was filed only on June 13, 1974, barely within the ten-year period. However, the Court noted the action could be barred even earlier, as the original title in Benedicto’s name (TCT No. 4169) was issued before the reconstitution, and the plaintiffs’ cause of action would have accrued from that earlier date. Given the uncontested evidence of Benedicto’s long-standing ownership and the plaintiffs’ inaction, the action was clearly barred by prescription. The Torrens title of Benedicto had long become indefeasible.