THE ACTION FOR RECONVEYANCE HAS NOT PRESCRIBED

The Defendants – Appellants assertion that the action for reconveyance has
already prescribed is untenable and should not be given weight. The heirs of the
late Tomas Manuel as, succeessors – in – interests of the deceased has not yet and
shall not prescribed in view of the fact that there action cannot be barred by the
fraudulent transfer of the original homestead patent of the late Tomas Manuel.

The herein plaintiffs – appellees fact of possession has never been put in
question during the trial because, the defendants – appellants in the present case
has never set their foot and has no knowledge as to the metes and bounds of the
properties they are claiming to be covered by the title in the name of their
predecessors – in – interests.

The fact of possession by the herein plaintiffs – appellees has all the right to
initiate the action for reconveyance considering the fact that they have always been
there in the land in dispute now. No amount of time could run that would make the
cause/s of action of the herein plaintiff would prescribed as he always hold on tho
their rights until such time that they have fully discovered what happened to the
title of their late father, Tomas Manuel.