Primary Holding

The dismissal of the amended complaint is upheld due to the failure to sufficiently state a cause of action and the expiration of the prescriptive period for the action.

Background

The case concerns a dispute over the ownership of properties transferred from the petitioner's name to the respondent's name, where the petitioner claims the transfer was based on void or voidable documents.

Facts

• 1. Eliza Zuniga-Santos claimed ownership of three parcels of land, which were transferred to Maria Divina Gracia Santos-Gran through a Deed of Sale. Eliza alleged that the transfer was based on void or voidable documents and that Maria Divina Gracia is the alleged daughter of her second husband with whom she had no children, and whose birth certificate was allegedly forged to make it appear that the latter was the petitioner's daughter.

Arguments of the Petitioners

• 1. Eliza Zuniga-Santos argued that the transfer of properties to Maria Divina Gracia Santos-Gran was based on void and voidable documents, warranting the annulment of the sale and reconveyance of the properties.

Arguments of the Respondents

• 1. Maria Divina Gracia Santos-Gran argued that the action had prescribed and that the Amended Complaint failed to state a cause of action because the void and voidable documents were not properly identified.

Issues

• 1. Whether the Amended Complaint states a cause of action.
• 2. Whether the action has prescribed.
• 3. Whether the dismissal of the Amended Complaint should be sustained.

Ruling

• 1. The Supreme Court ruled that the Amended Complaint failed to state a cause of action because it did not sufficiently establish the petitioner's right to the properties or provide adequate details about the allegedly void or voidable documents. The Court also held that the action had prescribed because it was filed more than ten years after the registration of the titles in the respondent's name, and the petitioner was not in possession of the properties.

Doctrines

• 1. Failure to State a Cause of Action: Occurs when the complaint's allegations are insufficient to establish the elements of a valid cause of action.
• 2. Prescription: The action for reconveyance based on implied trust prescribes in ten (10) years from the date of registration of the deed or issuance of the title, where the plaintiff is not in possession of the property.
• 3. Implied Trust: Created by operation of law when property is acquired through mistake or fraud, making the recipient a trustee for the benefit of the person from whom the property comes.

Precedents Cited

• 1. Macaslang v. Zamora: Distinguished between failure to state a cause of action and lack of cause of action.
• 2. Balo v. CA: Outlined the elements necessary for a complaint to state a cause of action.
• 3. Abad v. Court of First Instance of Pangasinan: Highlighted the need to state ultimate facts, not legal conclusions, in a pleading.
• 4. Spouses Alfredo v. Spouses Borras: Defined an action for reconveyance.
• 5. Spouses Aguirre v. Heirs of Lucas Villanueva: Explained the prescriptive periods for actions of reconveyance based on implied trust, depending on possession of the property.

Statutory and Constitutional Provisions

• 1. Article 1144 of the Civil Code: Pertains to prescription of actions based on written contracts.
• 2. Article 1456 of the Civil Code: Establishes implied trusts for property acquired through mistake or fraud.
• 3. Article 1409, Par. 2 of the Civil Code: N/A
• 4. Rule 16 of the Rules of Court: Discusses grounds for a motion to dismiss.
• 5. Rule 33 of the Rules of Court: Discusses Demurrer to Evidence.
• 6. Section 1, Rule 8 of the Rules of Court: States that the complaint need only allege the ultimate facts or the essential facts constituting the plaintiff's cause of action.