Cited Laws
TL;DR — Ruling
The petition is bereft of merit.
Accordingly, they have also become the riparian owners of the Second Accretion, and given that they have caused the issuance of OCT No. 21481 in their names over the said Accretion, they have also become the absolute owners thereof. Since Francisco, et al. took no action to protect their purported interests over the disputed accretions, the respondents titles over the same had already become indefeasible, to the exclusion of Francisco, et al. [34] At odds with the CAs disposition, Francisco et al. filed a motion for reconsideration which was, however, denied by the CA in a Resolution [35] dated May 7, 2008, hence, this petition taken by the latters heirs as their successors-in-interest. The Issue Before the Court The issue to be resolved by the Court is whether or not the CA erred in declaring that: ( a ) the descendants of Ciriaco are the exclusive owners of the Motherland; ( b )the descendants of respondent Victoriano are the exclusive owners of the First Accretion; and ( c ) the descendants of Pablo (respondents collectively) are the exclusive owners of the Second Accretion on the basis of the following grounds: ( a ) prescription of the reconveyance action, which was duly raised as an affirmative defense in the Amended Answer, and ( b ) the existence of an implied trust between the Imbornal sisters and Ciriaco. The Courts Ruling The petition is bereft of merit. A. Procedural Matter: Issue of Prescription. At the outset, the Court finds that the causes of action pertaining to the Motherland and the First Accretion are barred by prescription. An action for reconveyance is one that seeks to transfer property, wrongfully registered by another, to its rightful and legal owner. [36] Thus, reconveyance is a remedy granted only to the owner of the property alleged to be erroneously titled in anothers name. [37] As the records would show, the Amended Complaint filed by petitioners predecessors-in-interest, Francisco, et al. is for the reconveyance of their purported shares or portions in the following properties: (a) the Motherland, originally covered by OCT No. 1462 in the name of Ciriaco; (b) the First Accretion, originally covered by OCT No. P-318 in the name of respondent Victoriano; and (c) the Second Accretion, covered by OCT No. 21481 in the name of all respondents. To recount, Francisco, et al. asserted co-ownership over the Motherland, alleging that Ciriaco agreed to hold the same in trust for their predecessors-in-interest Alejandra and Balbina upon issuance of the title in his name. Likewise, they alleged that respondents acquired the First and Second Accretions by means of fraud and deceit. When property is registered in anothers name, an implied or constructive trust is created by law in favor of the true owner. [38] Article 1456 of the Civil Code provides that a person acquiring property through fraud becomes, by operation of law, a trustee of an implied trust for the benefit of the real owner of the property. An action for reconv
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