Varsity Hills Inc. vs.

Navarro
43 SCRA 503

Facts:
A petition was filed by the respondents Mejia as heirs of Quintin Mejia and by Elpidio Tiburcio as assignee of a
portion of the estate left by the latter as plaintiff against petitioners Tuason et. al. The complaint alleged that Quintin
Mejia had obtained a Spanish title to the land and that he and his successors in interest had occupied the land
without interruption until they were forcibly rejected there from and their houses demolished in1934 through a writ of
execution. In 1914, the defendants Tuason had obtained a decree of registration covering 35,403 hectares and that
they had fraudulently and insidiously included plaintiffs land in the area covered by the Certificate of Transfer by
inserting fake and false technicaldescriptions. UP et al. as subsequent acquirerswhose titles are derived from the
original fraudulentcertificates should likewise be annulled. Herein Petitioners contend that the decision in a civilcase
wherein the Respondents were declared aswithout title to the land and ejected by a writ of execution was affirmed
by the Supreme Court. ThePetitioners contend in the present case that thecauses of action averred by the
Respondents werebarred by the LRA and the statute of limitations over51 years having elapsed since the decree of
registration was issued, barred by laches as 32 yearshave elapsed since the ejectment and that the courthad no
jurisdiction to review and revise the decree of registration. They also maintain as affirmativedefenses that they had
in possession for over 30years of the land thus acquiring title by acquisitiveprescription and that claims for
ownership wereextinguished by the decree and that they arepurchasers for value and in good faith of the
landsstanding in their names. A motion to dismiss wasfiled yet was denied by the lower court. ThePetitioners
resorted to the SC for a specialproceeding for writs of certiorari and prohibition thusthe trial court was enjoined from
proceeding with thetrial until further orders.Mejia and Tiburcio claim that appeal in due time wasthe proper remedy.

Issue:
Whether or not the present action prospers based on claims of implied/constructive trust?

SC:
The court below gravely abused its discretion in denying petitioners motion to dismiss based on theiraffirmative
defenses. The action by Tiburcio andMejias was already barred by res judicata andextinctive prescription. A
previous case was decided wherein Quintin Mejia had been found without title and thus ejected. The action in the
court below was definitely barred as while the present respondents were not parties to the cause which Quintin
Mejia was such a party, the final judgment against him concludes and bars his predecessors and privies as well.
Since the respondents failed to file a petition for review of the decree within one year after the entry thereof despite
claims that there was fraud in the inclusion of their land in the title, they are barred by the LRA. However if the fraud
had been committed after the issuance of the decree, they should have pleaded when Quintin was made a
defendant in Civil Case 4420. Nevertheless, their cause of action is barred by resjudicata. With or without judgment
against Quintin, their action had been extinguished by the lapse of 30 years from the time he was ejected from the
land in question. An action to recover is also foreclosed by the statute of limitations. Actions on implied trusts are
extinguished by laches or prescription of 10 years.