Feliciana Licayan Tale v. The Honorable Court of Appeals

Summary

This Supreme Court case involves a land ownership dispute over 2.5 hectares wrongfully included in respondent's title. Petitioner Feliciana Tale inherited land from her father covered by OCT No. 125. Respondent Paterno Talisik, who married into the family, fraudulently included 2.5 hectares of petitioner's land in his own 1972 title when he only legitimately owned 2.5 hectares given by his father-in-law. The RTC ruled for petitioner, but the Court of Appeals reversed based on four-year prescription. The Supreme Court corrected this error, establishing that reconveyance actions based on constructive trust prescribe in ten years under Civil Code Article 1144, not four years. The Court reinstated the RTC decision, affirming petitioner's ownership and ordering reconveyance. This case clarified the important legal principle regarding prescription periods for land reconveyance actions in Philippine jurisprudence.