Rogelia Daclag v. Elino Macahilig

Summary

This Supreme Court Resolution involved a property reconveyance dispute where respondents sought to recover land fraudulently registered in petitioner Rogelia Daclag's name. The Court ruled that the deed of sale from Maxima to petitioners was null and void since Maxima was not the actual owner of the property. While initially applying a 10-year prescriptive period for fraudulent registration, the Court clarified that actions for reconveyance based on void contracts are actually imprescriptible under Article 1410 of the Civil Code. The Court partially granted petitioners' motion for reconsideration, modifying the damages award to recognize their good faith possession until service of summons in 1991, when legal interruption occurred. Petitioners were ordered to pay respondents 10 cavans of palay per annum beginning August 5, 1991, rather than from 1984, acknowledging their entitlement to fruits during the period of good faith possession before being legally notified of the defects in their title.