Bueno v. Reyes, GR No. L-22587 (Apr.

28, 1969)

FACTS
 On January 7, 1936, Francisco H. Reyes filed an answer in Cadastral Case No. 47 claiming Lot No. 2357 as
property belonging to himself and to his two brothers. Such case was heard without opposition and the lot was
adjudicated in their favor and the corresponding Certifcate of Title was issued in their name.
 Twenty-three years thereafer, or on December 12, 1962, the plaintiffs filed the action for reconveyance of the
subject lot alleging that:
 The lot originally belonged to Jorge Bueno, who died leaving three children, namely, Brigida, Eugenia, and
Rufino, to whom the property descended by intestate succession.
 Subsequently, Brigida and Eugenia died, leaving their children, who are now herein plaintiffs, together
with Rufino, in this case.
 Francisco H. Reyes was Eugenio’s husband and the father of the other plaintiffs surnamed Reyes.
 Francisco H. Reyes was entrusted in filing the answer in the cadastral proceedings and in obtaining the
title in behalf of all the heirs of Jorge Bueno, including his wife Eugenio.
 Subsequently, Francisco, either in bad faith or by mistake, filed an answer in the cadastral proceeding and
obtained title thereto in his name and those of his brothers, contrary to their agreement.
 Defendants, the brothers of Francisco, filed their answer, in which they raised a number of defenses, including
laches, imprescriptibility of title, and prescription of action.

ISSUE: Whether or not the action has already prescribed.

RULING
 SC held that what was apparently designed to be an express trust (the agreement of the parties of Francisco to
obtain the title in the behalf of the plaintiff) failed to materialize since Francisco instead acquired it in his and
his brothers’ name.
 Hence, if any trust can be deduced at all from the foregoing facts, it was an implied one, arising by operation of
law and not from any presumed intention of the parties but to satisfy the demands of justice and equity and as
a protection against unfair dealing or downright fraud.
 Thus, for instance, under Article 1456 of the Civil Code, “if property is acquired through mistake or fraud, the
person obtaining it is, by force of law, considered a trustee of an implied trust for the benefit of the person
from whom the property comes.”
 This would justify an action for reconveyance.
 The Court also held that although there are some decisions which hold that an action upon a trust is
imprescriptible, such does not distinguish betwen express and implied trusts. The better rule, as laid down by
the Court in other decisions, is that prescription does supervene where the trust is merely an implied one.
 The lower court are correct in ruling that the action for reconveyance is subject to prescription of ten years.
 The cause of action upon such trust must be deemed, however, to have accrued only upon the discovery of
the bad faith or mistake.
 In this case, the action accrued upon the discovery by the plaintiffs that Francisco, in violation of their
agreement with him, had obtained registration of the property in his own name and in the names of his
brothers.
 Thus, the action had not yet prescribed.
 On top of all this, it was the plaintiffs who were in possession of hte property as owners, continuoulsy up to
1962, when for the first time the defendants appeared upon the scene and tried to get such possession,
thereby revealing to them the fact of the mistaken or fraudulent registration.
 THE FOREGOING, OF COURSE, ARE NOT FACTS ALREADY ESTABLISHED BY EVIDENCE AND ARE DUBITABLE.
 WHEREFORE, the order appealed by plaintiffs is set aside and the case is REMANDED for further proceedings.