Heirs of Teodoro Tulauan v · G.R. 248974

Petitioner: Heirs of Teodoro Tulauan
Respondent: Manuel Mateo; Magdalena Mateo Lorenzo
Citation: G.R. No. 248974
Court: Supreme Court
Division: Third Division
Ponente: Inting, J.
Decided: September 7, 2022

Summary

The Supreme Court reversed the dismissal of an action for reconveyance filed by heirs of land owner Teodoro Tulauan against persons who obtained titles over their property. The RTC and CA dismissed the case for prescription, laches, and passage to innocent purchasers. However, the Supreme Court found that despite using the word 'fraudulent,' the complaint was actually based on an alleged inexistent deed of conveyance. Under Article 1410 of the Civil Code, actions to declare the inexistence of contracts are imprescriptible. The Court ruled that factual issues regarding laches and innocent purchaser status require full trial, not summary dismissal. The case was remanded to the RTC for trial on the merits, establishing important precedent on distinguishing between fraud-based and inexistence-based reconveyance actions and their respective prescriptive periods.

Statutes applied

Civil Code, Art. 1410

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By Intellegal Editorial Board · September 7, 2022

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