In Alejandro Millena v. Court of Appeals and Felisa Jacob, the Supreme Court affirmed that an action for reconveyance, seeking to transfer land title to the rightful owner, cannot be barred by prescription if the plaintiff (Felisa Jacob) is in actual possession of the land. This ruling underscores the principle that long-term, demonstrable possession of property can outweigh a seemingly valid paper title obtained through questionable means. It protects individuals who have maintained control and use of their land against those who attempt to claim ownership based on technical or fraudulent titles, highlighting the importance of continuous and actual possession in land disputes.

When Paper Promises Crumble: The Tale of Contested Land in Daraga, Albay

The heart of this case lies in a dispute over a 3,934-square meter parcel of land in Barangay Balinad, Daraga, Albay. Originally part of a larger estate, Lot 1874, the land was subject to a cadastral proceeding in the 1920s. The claimants, Gregoria Listana and Potenciana Maramba, along with Maramba’s children, reached a compromise in 1926 to divide the land. Listana received approximately one-fourth of the lot, a portion which would later become the epicenter of a protracted legal battle. The key question is this: Can a paper title, obtained through a free patent, override decades of actual, continuous possession of land?

Following the compromise agreement, Gregoria Listana, anticipating her death from tuberculosis, granted her cousin Antonio Lipato a power of attorney to sell her share of Lot 1874, with the proceeds intended for her burial. Lipato sold Listana’s portion to Gaudencio Jacob. After Gregoria died on the same day of the sale, Jacob took possession of the land and began harvesting coconuts. This act sparked a legal challenge from Potenciana Maramba, who filed an ejectment case against Jacob. However, the Justice of the Peace ruled in favor of Jacob, acknowledging his right to possession based on the deed of sale.

For nearly forty years, Gaudencio Jacob maintained peaceful and continuous possession of the one-fourth portion of Lot 1874. In 1966, Jacob and his children executed an extrajudicial settlement, formally adjudicating the 3,934-square meter portion to Felisa Jacob, his daughter. Subsequently, Felisa declared the land as her property and diligently paid the corresponding real property taxes, solidifying her claim of ownership. Years later, sometime in November 1981, Felisa discovered that Florencio Listana, son of Potenciana Maramba, had obtained Free Patent Certificate of Title No. VH-23536 in 1980, covering the entire 14,284-square meter area of Lot 1874, including the portion rightfully belonging to Felisa.

Felisa Jacob promptly filed a protest with the Bureau of Lands in Legazpi City, asserting her ownership of the one-fourth portion of Lot 1874, which she acquired through the extrajudicial partition in 1966. She alleged that Florencio Listana secured the title through misrepresentation and deceit, and sought the annulment of the Free Patent issued in Listana’s name. Despite Felisa’s protest, the heirs of Florencio Listana sold the entire Lot 1874, including the disputed portion, to Alejandro Millena in 1986. Millena, a nephew of Florencio Listana and grandson of Potenciana Maramba, was issued Transfer Certificate of Title No. T-71657, covering the whole of Lot 1874. This prompted Felisa Jacob, through her attorney-in-fact, to file a complaint against Millena for annulment of title, reconveyance, preliminary injunction, and damages in 1992.

The Regional Trial Court (RTC) ruled in favor of Felisa Jacob, ordering Millena to reconvey the 3,934-square meter portion to her and awarded attorney’s fees. The Court of Appeals (CA) affirmed the RTC’s decision, but deleted the award of attorney’s fees. Millena then appealed to the Supreme Court, raising issues of prescription, authentication of documents, and the correctness of the reconveyance order. The Supreme Court, in its analysis, focused on whether prescription barred the action for reconveyance, given that the title was procured in 1980 and the action was filed in 1992. The Court also scrutinized the authenticity of the documents used as the basis for the decisions of the lower courts.

The Supreme Court emphasized that prescription cannot be invoked against an action for reconveyance if the plaintiff is in possession of the land. Article 523 of the Civil Code defines possession as “the holding of a thing or the enjoyment of a right.” This definition includes two essential elements: control of the thing and a deliberate intention to possess it. The Court found that Felisa Jacob had indeed exercised dominion over the contested parcel of land. After acquiring the property in 1966, she instructed her nephew, Jaime Llaguno, to act as caretaker, made improvements on the land, and consistently paid property taxes. These actions demonstrated her control over the land and her clear intention to possess it, thus negating Millena’s claim of prescription.

Millena also questioned the authenticity of several crucial documents, including the compromise agreement, the Justice of the Peace decision, the power of attorney, and the deed of sale. As the authenticity of documents is a factual question, the Supreme Court typically defers to the findings of the Court of Appeals. However, in the interest of justice, the Court thoroughly examined the points raised by Millena. It found that the Justice of the Peace decision, being a public document, was admissible as evidence without further proof of its execution or genuineness. The decision, signed by Justice of the Peace Manuel M. Calleja and bearing the court’s seal, confirmed the existence of the compromise agreement, power of attorney, and deed of sale, and since no appeal was made, the decision had long become final.

Regarding the reconveyance, the Court reiterated that after one year from entry, a decree of registration is generally incontrovertible, even if fraud attended its issuance. However, the law allows an aggrieved party to bring an action for reconveyance to address fraud or improper technicalities, provided the property has not been transferred to an innocent purchaser for value. In this case, Felisa Jacob presented substantial evidence of her ownership claim, including her continuous possession since 1966 and her predecessor-in-interest’s lawful possession since 1926, along with tax declarations. The Court held that possessing a certificate of title alone does not automatically make the holder the true owner, especially when the registration proceedings are used as a shield for fraud or enrichment at another’s expense. Therefore, the inclusion of Felisa Jacob’s 3,934-square meter portion in Florencio Listana’s Free Patent Certificate Title was deemed erroneous and irregular.

Furthermore, Millena argued that he was an innocent purchaser for value, which would protect him from an action for reconveyance. However, the Court rejected this argument, stating that a purchaser in good faith buys property without notice of another’s right or interest. The Court found that Millena had actual knowledge of facts that should have prompted a prudent purchaser to inquire further into the title’s validity. Millena lived beside the contested land, and his own kitchen encroached on it, suggesting he was aware of Jacob’s claim. A witness, Lucio Londonio, testified that Jacob originally owned the land, which was later transferred to Felisa Jacob, and that he regularly saw Jacob’s caretaker planting crops on the land. Additionally, Millena admitted during cross-examination that he knew about Felisa Jacob’s protest before the Bureau of Lands against Florencio Listana in 1981. This evidence collectively demonstrated that Millena was not a purchaser in good faith.

The Supreme Court highlighted the interplay between paper titles and actual possession, underscoring that continuous and demonstrable possession can create a stronger claim than a title obtained through dubious means. Millena’s claim of being an innocent purchaser for value was discredited by his proximity to the land, his knowledge of prior disputes, and his own encroachment onto the property. The Court emphasized that land registration proceedings should not serve as a shield for fraud or unjust enrichment, and that the right to ownership must be grounded in fairness and equity. Ultimately, the Supreme Court denied the petition, affirming the Court of Appeals’ decision and ordering Millena to reconvey the contested portion of Lot 1874 to Felisa Jacob.

FAQs

What was the key issue in this case?	The central issue was whether Felisa Jacob’s action for reconveyance was barred by prescription, given that Alejandro Millena held a certificate of title to the disputed land. The Court also examined whether Millena was an innocent purchaser for value.
What is an action for reconveyance?	An action for reconveyance is a legal remedy sought to transfer or reconvey land from a registered owner to the rightful owner, particularly when the title was obtained through fraud or mistake. It acknowledges the validity of the title but seeks to correct the ownership based on equitable grounds.
What does it mean to be an ‘innocent purchaser for value’?	An innocent purchaser for value is someone who buys property without notice of any other person’s right to or interest in that property. This status typically protects a buyer from claims against the property that existed before the purchase.
How did the Court define ‘possession’ in this case?	The Court defined possession based on Article 523 of the Civil Code, stating that it involves “the holding of a thing or the enjoyment of a right.” It requires both control over the property and a deliberate intention to possess it.
What evidence did Felisa Jacob present to prove her possession?	Felisa Jacob presented evidence including her instruction to her nephew to act as caretaker, her improvements on the land, and her consistent payment of property taxes since 1967. These actions demonstrated her control and intent to possess the land.
Why was Millena not considered an innocent purchaser for value?	Millena was not considered an innocent purchaser because he had knowledge of facts that should have prompted a prudent purchaser to investigate further. This included his proximity to the land, his kitchen’s encroachment, and his awareness of Felisa Jacob’s prior protest.
What was the significance of the Justice of the Peace decision in this case?	The Justice of the Peace decision, which ruled in favor of Gaudencio Jacob in an earlier ejectment case, was significant because it confirmed the validity of the sale from Gregoria Listana to Gaudencio Jacob. It also established Jacob’s right to possess the contested land.
What is the prescriptive period for an action for reconveyance?	The prescriptive period for an action for reconveyance depends on the basis of the action. If based on fraud, it must be filed within four years from the discovery of the fraud. If based on an implied or constructive trust, it prescribes in ten years from the issuance of the original certificate of title.
How did the Court address the issue of prescription in this case?	The Court held that prescription cannot be invoked in an action for reconveyance when the plaintiff is in possession of the land. Since Felisa Jacob was found to be in possession of the contested land, the prescriptive period did not apply.

This case reaffirms the importance of actual possession in land ownership disputes and highlights the principle that paper titles alone do not guarantee ownership. It underscores that long-term, demonstrable possession, coupled with clear intent, can outweigh a seemingly valid paper title, especially when the title was obtained through questionable means. The ruling provides a safeguard for those who have maintained continuous control and use of their land, protecting them against claims based on technical or fraudulent titles.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Alejandro Millena v. Court of Appeals and Felisa Jacob, G.R. No. 127797, January 31, 2000