Heirs of Gaudencio Blancaflor v. Court of Appeals

Summary

This case involves a property dispute arising from an execution sale. In 1968, Gaudencio Blancaflor lost a civil case and his property was sold at execution to satisfy the judgment. The purchaser, Sarmiento Trading Corporation, obtained proper certificates and court orders transferring title. However, Blancaflor retained the owner's duplicate certificate. Twenty years later, the current owner (Greater Manila Equipment Marketing Corporation) filed a petition to compel surrender of the duplicate certificate. The heirs argued the action had prescribed under Article 1144 of the Civil Code. The Supreme Court ruled that this was not enforcement of the original judgment but administrative completion of an already executed sale. Since proper inscriptions provided constructive notice and the redemption period had expired without redemption, the original owner was divested of all rights. The petition was properly filed under Section 107 of P.D. 1529, and prescription did not apply to such administrative proceedings.