Catalina Buan Vda. de Esconde v. Honorable Court of Appeals

Summary

This case involves a family dispute over inherited property where siblings challenged their brother's exclusive ownership of Lot No. 1700. The Supreme Court found that while the 1946 extrajudicial partition created a constructive implied trust due to the mother/guardian's mistake in favoring one heir, the action for reconveyance was barred by the 10-year prescriptive period and laches. The case was filed in 1987, over 40 years after the property's registration in 1947. The Court applied Article 1456 of the Civil Code regarding implied trusts arising from mistake, distinguishing constructive trusts where prescription runs without need for repudiation. While denying the petition, the Court ordered the defendant to indemnify his brother for improvements made on the contested lot, preventing unjust enrichment.