Spouses Jose Bejoc v. Prima Calderon Cabreros

Summary

This case involves a property dispute over two parcels of agricultural land originally owned by Maura Caputol, who donated them to her son Domingo in 1975. After Domingo's death in 1979, his widow Prima inherited the properties. The petitioner spouses, who were left as caretakers, allegedly created fraudulent documents to transfer ownership to themselves and obtained a free patent title in 1984. Prima filed for reconveyance in 1990. The Supreme Court affirmed lower courts' findings that petitioners held the property in implied constructive trust under Article 1456 of the Civil Code, having acquired it through fraud. The Court ruled that reconveyance actions based on implied trust prescribe in 10 years from title issuance, making Prima's 1990 action timely. The decision emphasizes that Torrens titles cannot perpetuate fraud against rightful owners.