VICENTE SAPTO VS. FABIANA

Category: Property, Ownership and Its Modifications

VICENTE SAPTO VS. FABIANA

Actions to quiet title to property in the possession of the plaintiff are imprescriptible.

FACTS:

The subject property was originally owned by Sapto (this Sapto was a Moro, so only one name) and located in Alambre, Toril, Davao City. He died, leaving three sons Samuel, Constancio, and Ramon. The latter predeceased his brothers, leaving no heirs. Samuel and Constancio executed a deed of sale for a portion of said property in favour of Fabiana in consideration of P240.00. The sale was approved by the governor of Davao but was never registered. The property was transferred to Fabiana and from then on he enjoyed possession from 1931 until the case was filed.

Constancio died with no issue, leaving Samuel as sole administrator of the property. Upon the latter’s death, his widow and two children filed the present action for recovery of the parcel of land sold by their predecessors to defendant. The CFI held that although the sale between the Sapto brothers and Fabiana was never registered, it was binding valid and binding upon the parties and the vendors’ heirs. The CFI also ordered the petitioners to execute the necessary deed of conveyance in favour of the defendant.

Hence this appeal.

ISSUE:

Whether or not the CFI’s order of conveyance in favour of Fabiana was valid.

HELD:

The SC first affirmed the validity of the sale between the Sapto brothers and Fabiana, ruling, that even though it was never registered the sale was valid, binding, and effective upon the heirs of the vendor. According to the court, actual notice of the sale served as registration. Futher, that the transfer and possession of the property was a clear indication of the validity of the sale.

Regarding the issue on the validity of the order of conveyance, the SC ruled that it was valid. In assailing the order, the Sapto heirs claimed that the CFI cannot order the conveyance because the defendant’s cause of action had already prescribed.

The SC ruled however, that the action for conveyance was actually one to quiet title. In ruling so, the SC cited American jurisprudence and Art. 480 of the New Civil Code, which states, that actions to quiet title to property in the possession of the plaintiff are imprescriptible.
The judgement is affirmed, cost against appellants.