View full case

HEIRS OF FRANCISCO I. NARVASA v. IMBORNAL

FACTS:

The disputed property is the Motherland, a parcel of land in Batangas. It was initially owned by Ciriaco, who sold it to Gregorio de Vera. However, the heirs of Ciriaco and de Vera were not included in this case.

The RTC ruled in favor of Francisco and other plaintiffs, ordering the respondents to reconvey their portions of the Motherland and its accretions. The RTC found an implied trust between Ciriaco and the Imbornal sisters. It also ruled that the owner of the Motherland is the owner of the adjacent accretions.

The CA reversed the RTC decision, declaring exclusive ownership of the Motherland to the descendants of Ciriaco, the First Accretion to the descendants of Victoriano, and the Second Accretion to the descendants of Pablo. The CA held that Ciriaco's homestead patent made his title to the Motherland indefeasible and that the respondents acquired title to the accretions by prescription.

The plaintiffs filed a motion for reconsideration, which was denied. They then brought the case to the Supreme Court, questioning the CA's declaration of exclusive ownership based on prescription and the implied trust between the Imbornal sisters and Ciriaco.

ISSUES:

  1. Whether the causes of action pertaining to the Motherland and the First Accretion are barred by prescription.

  2. Whether an implied trust exists between the Imbornal sisters and Ciriaco with respect to the Motherland.

  3. Whether the Imbornal sisters have proven the existence of an implied trust over the Motherland and their ownership rights over the First and Second Accretions.

  4. Whether the petitioners have ownership rights over the accretions

  5. Whether the petitioners have acquired the properties through prescription

RULING:

  1. The causes of action pertaining to the Motherland and the First Accretion are barred by prescription. An action for reconveyance based on an implied trust prescribes in ten (10) years from the date of registration of the deed or the date of issuance of the certificate of title over the property, unless the plaintiff is in possession of the property. In this case, the Amended Complaint was filed way beyond the 10-year period to seek the reconveyance of the Motherland and the First Accretion, thus making the causes of action pertaining to these properties dismissed based on prescription.

  2. The existence of an implied trust between the Imbornal sisters and Ciriaco with respect to the Motherland was not established. An implied trust arises by operation of law to satisfy the demands of justice and equity and protect against unfair dealing or fraud. However, in this case, the burden of proving the existence of the implied trust lies on the party asserting its existence. Since the party failed to provide clear and satisfactory proof of the existence of the implied trust, the claim of co-ownership over the Motherland was not upheld.

  3. No, the Imbornal sisters failed to prove their ownership rights over the Motherland and their claim over the First and Second Accretions. It cannot be said, merely on the basis of oral evidence, that the Motherland had been either mistakenly or fraudulently registered in favor of Ciriaco. The court held that the evidence must be clear and trustworthy, and should not rest on loose, equivocal, or indefinite declarations. Furthermore, the oral testimony of the Imbornal sisters' successors would not effectively establish their claims of ownership, especially considering that the alleged agreement transpired decades ago. As the title to the Motherland had become indefeasible and there was a lack of evidence showing that it was acquired and registered by mistake or through fraud, the court ruled that Ciriaco and his heirs are the owners of the Motherland. Consequently, the Imbornal sisters' cause of action with respect to the First and Second Accretions also fails.

  4. The petitioners, being non-riparian owners, do not have ownership rights over the accretions, as alluvial deposits along the banks of a creek or river automatically belong to the owner of the estate to which it may have been added.

  5. The petitioners failed to prove that they acquired the properties through prescription as it was not established that they were in possession of any of them.

PRINCIPLES:

  • An action for reconveyance based on an implied trust prescribes in ten (10) years, unless the plaintiff is in possession of the property. (Lasquite v. Victory Hills, Inc.)

  • An implied trust arises by operation of law to satisfy justice and equity and protect against unfair dealing or fraud. (Article 1456, Civil Code)

  • Implied trusts must be proven by clear and trustworthy evidence.

  • Oral evidence for implied trusts should be considered with extreme caution.

  • Oral testimony, depending exclusively on human memory, is less reliable than written or documentary evidence.

  • The award of a homestead patent and the subsequent registration of the land are presumptively regular and proper.

  • The riparian or littoral owner has a preferential right to land formed by accretions or alluvial deposits due to the action of the sea, as recognized by Article 4 of the Spanish Law of Waters of 1866.

  • Alluvial deposits along the banks of a creek or river do not form part of the public domain and automatically belong to the owner of the adjoining property.

  • Ownership of accretions can only be claimed by riparian owners or those who can prove acquisition through valid means such as prescription.

  • The Torrens system requires the registration of alluvial property by the owner of the adjoining property to ensure clear ownership rights.

  • The burden of proof lies with the party claiming ownership or reconveyance of the property.