Heirs of Pomposa Saludares Represented By Isabel Dator v. Court of Appeals

Summary

This case involves a property ownership dispute over Lot 5793, part of the Tanza estate originally owned by Juan Dator and Pomposa Saludares. After Pomposa's death in 1923, her heirs partitioned the estate and obtained free patent title in 1977. Private respondents Jose Dator and Carmen Calimutan filed a reconveyance action in 1988, claiming ownership through purchase from Petra Dator's heirs and alleging fraud in the free patent application. The trial court dismissed the action for prescription, but the Court of Appeals reversed, ordering reconveyance. The Supreme Court ultimately reinstated the trial court decision, finding that the heirs were in continuous possession through their tenants, private respondents failed to prove actual possession, and the reconveyance action was barred by the 10-year prescription period under Civil Code Article 1144(2). The case establishes that reconveyance actions are subject to prescription unless the plaintiff remains in possession of the disputed land.