Spouses Ricardo Pascual v. Court of Appeals

Summary

Property title dispute where Remedios Eugenio-Gino sought to cancel title of Spouses Pascual over Lot Nos. 2-A and 2-E, claiming fraudulent acquisition of area exceeding seller Canuto Sioson's actual share, and asserting ownership through unprobated will of Catalina Sioson. Supreme Court dismissed the case on two grounds: prescription (action filed over 19 years after title registration, exceeding 10-year limit for implied trust actions which run from registration date, not actual notice) and lack of real party-in-interest status (unprobated will confers no property rights under Article 838 of Civil Code). Case establishes that implied trust actions prescribe in 10 years from registration of adverse title, and that beneficiaries under unprobated wills cannot claim property rights until probate court admits the will.