National Development Co. v. Hon. Court of Appeals

Summary

This case involved a dispute over reconveyance of corporate shares allegedly transferred under duress during martial law. Private respondents claimed they were forced to transfer their 75% controlling interest in Continental Bank to Disini-controlled corporations while Vicente Tan was under military detention. The shares eventually passed to NDC and then partially to AMEX. Private respondents sued for reconveyance claiming constructive trust, but the Supreme Court ruled that the action was barred by prescription and that the complaint failed to state a cause of action against subsequent transferees rather than the original assignees. The Court held that prescription was not interrupted by martial law detention since Tan actively pursued legal remedies during his detention. The case established important precedents regarding prescription of actions for recovery of movables, the necessity of joining indispensable parties in reconveyance actions, and the limits of martial law as a fortuitous event interrupting prescription periods.