Narciso Buenaventura v. Hon. Court of Appeals

Summary

The Buenaventura siblings claimed entitlement to inherit one-third of a government lot as heirs of Julian Caiña, but alleged the lot was fraudulently sold only to other heirs (Lorenzo and Francisca) in 1965 and subsequently transferred to Manotok Realty in 1966. They filed suit in 1976 seeking reconveyance based on fraud and simulation. The Supreme Court affirmed dismissal of their complaint, ruling that their action for reconveyance based on fraud was time-barred under the 10-year prescription period for actions based on constructive trust, and additionally barred by laches. The Court emphasized that prescription rules are designed to protect innocent purchasers for value against parties who unreasonably delay asserting their rights, noting that allowing such belated claims would be anathema to good order in property transactions.