**Facts:**
The case originated from a Deed of Partition executed on April 5, 1937, among the heirs of Bernardo Cavile and Tranquilina Galon, dividing several parcels of land in Negros Oriental. The heirs included their legitimate children and Bernardo’s children from a previous marriage. Two lots in question were sold to their co-heir, Castor Cavile, making him their sole owner.
On August 5, 1960, Castor and his sister Susana executed a Confirmation of Extrajudicial Partition, wherein Castor acknowledged Susana’s ownership over two particular parcels of land that closely matched the description of lots in the 1937 Deed of Partition.
In 1974, respondents (Justina Litania-Hong, accompanied by her husband and her sister, the heirs of Susana) filed a complaint against the petitioners for reconveyance and recovery of property with damages, claiming the lots were inherited from Susana, who had obtained them from her parents, and were subsequently usurped by the petitioners. The petitioners countered this by asserting ownership through the Deed of Partition, later sales, and possession.
The Regional Trial Court (RTC) ruled in favor of the petitioners, dismissing the respondents’ claims. Upon appeal, the Court of Appeals reversed the RTC’s decision, favoring the respondents and ordering the reconveyance of the properties in question to them. The petitioners then elevated the case to the Supreme Court.
**Issues:**
1. Whether the Confirmation of Extrajudicial Partition executed by Castor Cavile and Susana Cavile can vary the terms of the Deed of Partition, which was not contested.
2. Whether the complaints filed by the respondents should have been dismissed on the grounds of res judicata or forum shopping.
3. Whether the free patent titles issued to the petitioners can be reconveyed to the respondents.
**Court’s Decision:**
The Supreme Court granted the petition, reversing and setting aside the decision of the Court of Appeals and reinstating the RTC’s decision declaring the petitioners as the absolute owners of the parcels of land in dispute. The basis for the decision includes the recognition of the Torrens title in the petitioners’ names, the inadequacy of the respondents’ evidence, particularly the tax declarations, and the failure to convincingly demonstrate their possession or the fraud alleged against the petitioners. The action for reconveyance was also deemed time-barred.
**Doctrine:**
– Tax declarations are not conclusive evidence of ownership.
– A Torrens title becomes indefeasible one year after the issuance of the patent, and only the government can challenge its issuance unless fraud is proven by the affected party within the prescribed period.
– Actions for reconveyance based on implied or constructive trust prescribes in 10 years from the issuance of the Torrens title.
**Class Notes:**
1. **Torrens System:** Provides a method for the definitive and indefeasible titling of properties.
2. **Prescription for Reconveyance:** Actions based on implied or constructive trust must be filed within 10 years from issuance of the title.
3. **Deed of Partition vs. Confirmation of Extrajudicial Partition:** A deed of partition that has not been contested is definitive in the absence of compelling and more convincing evidence to the contrary.
4. **Evidence of Ownership:** Ownership cannot be proved by tax declarations alone; a higher degree of proof, such as a valid title, is required.
5. **Fraud Allegations:** Must be proven with specific and intentional acts designed to deceive.
**Historical Background:**
The case underscored the conflicts that can arise from family partitions of estate without adequate documentation and clear legal steps, revealing the complexities of property disputes in Philippine legal history. These disputes often escalate to the highest court, demonstrating the enduring challenges surrounding land ownership, inheritance rights, and the legal recognition of property titles under the Torrens system.
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