Heirs of Maria Revilleza Vda. de Vega v. Court of Appeals

Summary

This Supreme Court case involved a property dispute over inherited land originally owned by Ignacio Revilleza. The deceased's heirs partitioned the land in 1915, with Antonio Tamisin receiving one parcel. In 1921, while Antonio was allegedly serving in the US Navy abroad, a deed of sale ('Escritura de Venta Absoluta') purportedly transferred his land to Sebastian Salva Cruz and Lorenzo Revilleza. Antonio's heirs later filed for reconveyance, claiming the deed was forged. The trial court dismissed the case due to prescription and insufficient evidence. The Court of Appeals reversed, finding the deed was fraudulent and ordering reconveyance. However, the Supreme Court reinstated the trial court's dismissal, ruling that the action for reconveyance based on constructive trust had prescribed under the 10-year limitation period, as it should have been filed within 10 years from when the adverse claim became apparent (1929 for registered land, 1945 for unregistered portion). The case demonstrates the importance of prescription periods in property disputes and proper characterization of causes of action.