Salvatierra v. Court of Appeals

G.R. No. 107797 (August 26, 1996)

Facts:

The case revolves around the estate of Enrique Salvatierra, who died intestate in 1930, leaving behind three parcels of land. His legitimate siblings, including Tomas, Bartolome, Venancio, Macario, and sister Marcela, were his heirs. In 1966, Macario Salvatierra sold Lot No. 26 to his son, Anselmo Salvatierra, for P1,000. Meanwhile, Marcela sold her share of the estate to Venancio, and Bartolome's heirs sold their share to Tomas.

On September 24, 1968, an "Extrajudicial Partition with Confirmation of Sale" was executed among the heirs, which detailed the distribution of the estate. Anselmo was assigned 405 sq. m. of Lot No. 26, while Venancio was assigned a portion of Lot No. 26 and Lot No. 27. However, on June 15, 1970, Venancio sold a 149-sq. m. portion of Lot No. 26 to spouses Lino Longalong and Paciencia Mariano, who took possession of the property.

In 1982, a survey revealed that the 149 sq. m. portion was outside the Longalongs' fence, leading to the discovery that Anselmo had obtained a title for the entire Lot No. 26, which measured 749 sq. m. Efforts to resolve the issue amicably failed, prompting the Longalongs to file a case for reconveyance against Anselmo and his heirs.

The Regional Trial Court (RTC) dismissed the case, ruling that the Longalongs failed to establish ownership and that the four-year prescriptive period for filing the action had lapsed. The Longalongs appealed to the Court of Appeals, which reversed the RTC's decision, ordering the reconveyance of the 149 sq. m. portion and awarding attorney's fees.

Legal Issues:

1. Which prescriptive period applies to actions for annulment: the four-year period under Article 1391 of the New Civil Code or the ten-year period under Article 1144?
2. Was there a double sale of Lot No. 26, and did Anselmo Salvatierra have the right to sell the entire lot?

Arguments:

• Petitioners (Anselmo Salvatierra's heirs):

  • They argued that the RTC's dismissal was correct, asserting that the Longalongs failed to prove ownership and that the action was barred by the four-year prescriptive period from the discovery of the alleged fraud.
  • They contended that the case involved a double sale, which should be governed by Article 1391.

• Respondents (Longalong spouses):

  • They contended that they had established ownership of the 149 sq. m. portion through the sale from Venancio and that the prescriptive period for reconveyance is ten years, as established by Article 1144.
  • They argued that Anselmo's registration of the entire Lot No. 26 was fraudulent since he was only entitled to 405 sq. m. based on the extrajudicial partition.

Court's Decision and Legal Reasoning:

The Court of Appeals ruled in favor of the Longalongs, emphasizing that Anselmo Salvatierra could only sell his pro indiviso share of Lot No. 26, which was 405 sq. m. The court found that Anselmo's act of registering the entire lot was done with intent to defraud the other heirs, particularly Venancio, who was entitled to the remaining portion of Lot No. 26.

The court clarified the applicable prescriptive period for actions for reconveyance based on implied or constructive trust, stating that such actions are governed by Article 1144, which prescribes a ten-year period from the date the right of action accrues. The court noted that the Longalongs filed their action within this period, as it was only five years after Anselmo obtained the title.

The court also highlighted the importance of the extrajudicial partition document, which clearly delineated the shares of the heirs and established that Anselmo's claim to the entire lot was unfounded. The court concluded that the lower court erred in its interpretation of the law regarding prescription and ownership.

Significant Legal Principles Established:

1. The prescriptive period for actions for reconveyance based on implied or constructive trust is ten years from the date the right of action accrues, as per Article 1144 of the New Civil Code.
2. A vendor can only sell what he owns or is authorized to sell, and any sale beyond that is voidable.
3. The extrajudicial partition serves as a binding agreement among heirs, clearly defining their respective shares in the estate.