Cipriano Bacomo v. Heirs of the Late Teodulo Mingua, Sr.

Summary

The Supreme Court denied the petition for reconveyance filed by heirs of Cipriano Bacomo against heirs of Teodulo Mingua Sr. over 20,002 square meters of land. While correcting the Court of Appeals' ruling on prescription (finding that actions based on void contracts are imprescriptible under Article 1410), the Court ultimately ruled against petitioners on the merits. The Court found that valid notarized deeds of conveyance existed proving legitimate sales to Teodulo in 1939 and 1958, totaling 26,195 square meters. Petitioners failed to prove by clear and convincing evidence that no deeds existed, and the property had already passed to an innocent purchaser for value (Puerto Princesa City Government), precluding reconveyance. The case establishes that actions for reconveyance based on alleged void contracts are imprescriptible, but plaintiffs must still prove their claims by clear and convincing evidence and the property must not have passed to innocent third parties.