Marlene Crisostomo & Jose G. Crisostomo v. Florito M. Garcia, Jr.

Summary

This case involves a property dispute where Garcia purchased land from Victoria Garcia in 1986, but before he could complete title transfer, the seller's son and daughter-in-law (the Criostostomos) fraudulently obtained title and used the property as loan collateral. Garcia sued for reconveyance in 2002, with petitioners claiming the action had prescribed. The Supreme Court resolved the prescription issue, ruling that actions for reconveyance based on constructive trust prescribe in 10 years from title registration, not from the original sale. Since title was registered in 1993 and suit filed in 2002, the action was timely. The case established important precedent on prescription periods for reconveyance actions based on fraudulent registration versus actions on the underlying contract.