G.R. No. 50422 February 8, 1989
NICOLAS ARRADAZA, et al., petitioners, vs. HONORABLE COURT OF APPEALS and MELCHOR LARRAZABAL, respondents.

FACTS

The petitioners are the heirs of spouses Ignacio Arradaza and Marcelina Quirino. In 1941, the spouses purchased a parcel of land in Ormoc, Leyte, but the deed of sale was lost during the war. Consequently, the land was erroneously adjudicated to the original vendors in cadastral proceedings. In 1944, Ignacio mortgaged the land. After Marcelina’s death in 1944, Ignacio sold the entire property to the mortgagee, Estelita Magalona Bangloy, in 1947. Bangloy subsequently sold the land to the private respondent, Melchor Larrazabal, in 1963. Larrazabal obtained a Transfer Certificate of Title in his name after the registered owners executed a deed of quitclaim in favor of Ignacio Arradaza.
In 1975, the petitioners filed an action to recover their alleged one-half pro-indiviso share in the land as heirs of Marcelina Quirino. They contended that Ignacio’s 1947 sale was void as to their mother’s share, which had passed to them by succession upon her death. The trial court rendered a summary judgment dismissing the complaint, which the Court of Appeals affirmed. The petitioners elevated the case to the Supreme Court via certiorari.

ISSUE

The main issue is whether the petitioners’ action to recover their alleged share in the property has prescribed or is barred by laches.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court ruled that the action had indeed prescribed and that the petitioners were guilty of laches. While the petitioners argued that the sale by their father was void as to their mother’s share, making the defect incurable by prescription, the Court found that the applicable prescriptive period had lapsed. An action for reconveyance based on an implied or constructive trust prescribes in ten years from the issuance of the title, which operates as a constructive notice. The title was issued to Larrazabal in 1963, but the suit was only filed in 1975, beyond the ten-year period.
Furthermore, the Court emphasized the doctrine of laches. The petitioners slept on their rights for nearly three decades, from their father’s sale in 1947 until they filed suit in 1975, while the property was in the continuous possession of Bangloy and later Larrazabal, who paid taxes and improved the land. This unreasonable delay prejudiced the respondent, who was a purchaser in good faith and for value. The Court also upheld the propriety of the summary judgment, as the material facts were undisputed based on the affidavits, exhibits, and memoranda submitted during pre-trial, leaving no genuine triable issue of fact.