Balbin V Medalla

(RULE 74) Balbin v. Medalla, GR No.
L-46410, October 30, 1981

FACTS:
1. Private respondents purchased from the heirs of Juan Ladao and
agricultural land in Mamburao, Occidental, Mindoro and sought for
the application for registration of title
2. It was opposed by petitioners on the ground that they were
previously issued Original Certificates of title thru either
Homestead or Free Patent grants.
3. CFI of Occidental Mindoro rendered judgement in favor of in favour
of Respondents, since there exists a registered Information
Posesoria in the name of Juan Ladao from whom private
respondents Medalla bought the land.
4. It appears that before the filing of the present action for
reconveyance and annulment of titles on August 30, 1973, land
registration proceedings had been instituted by private
respondents covering the same lands involved in the aforesaid
action. Petitioners herein filed opposition to the application, but
because of the reservation of private respondents to file a separate
action for the cancellation of the original certificates of title issued
to petitioners herein, the land registration court abstained from
ruling on the petitioners' opposition.
5. Petitioners assail the validity of the registration which they claim to
have been done beyond the period of one year from April 17, 1894
to April 17, 1895, as allegedly required by the Royal Decree of
February 13, 1894 otherwise known as the Maura Law. (38 days
from the last day of the one-year period)
ISSUE: 1. The respondent judge of the court a quo erred in holding that
the lower court has jurisdiction over the nature and cause of action of
private respondents.
2. That respondent judge of the court a quo erred in holding that private
respondents' cause of action has not prescribed.
HELD: Petitioners have a better right to the land.
1.
Section 21 of the Maura Law invoked by petitioners themselves does

not speak of registration, but merely perfection of information title,
which, as already discuss may be done by instituting possessory
information proceedings within the said one-year period fixed by the
aforementioned Royal Decree of February 13, 1894, possibly ending in
the registration of the title, depending on the evidence presented.
What was required is merely the institution of a possessory information
proceeding within the one-year period as provided in the Royal Decree

of February 13, 1894 or the Maura Law.
This registration of the informacion posesoria must have followed as
the result or outcome of a possessory information proceeding
instituted by the late Juan Ladao in accordance with Section 19 of the
said Royal Decree of February 13, 1894, and commenced within the
one year period, pursuant to Section 21 of the same decree.
Otherwise, if this were not so, no registration of the said informacion
posesoria might have been effected in the Registry of Deeds of the
Province of Occidental Mindoro, for if the registration thereof on May
25, 1895 was violative of the decree, for being beyond the one-year
period from April 17, 1894 to April 17, 1895, the Register of Deeds
would certainly not have performed an illegal act.
Registration is the act of a government official and may not be
controlled by the private party applying for registration of his title.The
institution of the proper proceeding is clearly what is required to be
done within the one-year period by the party seeking to perfect his
title, not the registration thereof, if found legally warranted.
By its nature, therefore, registration may not necessarily be within the
same one-year period. If the required proceedings are instituted, as they
have to be before the corresponding title may be issued and registered,
the registration may be possible of accomplishment only after the one-year
period, considering the number of proceedings that might have been
instituted within the non-extendible period of one year. This is what
apparently happened in the instant case with the proceeding to perfect the
title commenced within the one-year period, but the registration of the
possessory information title done thereafter, or on May 25, 1895, after the
prescribed proceeding which is naturally featured with the requisite notice
and hearing.
2.
PRESCRIBED. An action for reconveyance of real property resulting

from fraud may be barred by the statute of limitations, which requires
that the action shall be filed within four (4) years from the discovery of
the fraud. Such discovery is deemed to have taken place when the
petitioners herein were issued original certificate of title through either
homestead or free patent grants, for the registration of said patents
constitute constructive notice to the whole world.
In the case at bar, the latest patent was issued on October 14, 1959.
There is, therefore, merit in petitioner's contention that "if any action
for reconveyance should be commenced, the same should be filed on
or before October 14, 1963. But private respondents' complaint for
reconveyance and annulment of titles with damages was filed only on
August 30, 1973, or more than 14 years had already elapsed from the
date of the issuance of the respective titles of the defendants.
Consequently, the action for reconveyance of land titled in the names
of defendants (petitioners herein) had already prescribed."

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(RULE 74) Balbin v. Medalla, GR No.

L-46410, October 30, 1981

Section 21 of the Maura Law invoked by petitioners themselves does

proceeding within the one-year period as provided in the Royal Decree

PRESCRIBED. An action for reconveyance of real property resulting

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