G.R. No. L-31956. April 30, 1984.
FILOMENA GERONA DE CASTRO, petitioner, vs. JOAQUIN TENG QUEEN TAN, TAN TENG BIO, DOLORES TAN, ROSARIO TAN HUA ING, and TO O. HIAP, respondents.

FACTS

In 1938, petitioner Filomena Gerona de Castro sold a residential lot in Bulan, Sorsogon to Tan Tai, a Chinese citizen. Tan Tai died in 1956, leaving his widow and children as respondents. Prior to his death, one of his sons, respondent Joaquin Teng Queen Tan, had become a naturalized Filipino citizen on August 11, 1956. Six years after Tan Tai’s death, on November 18, 1962, his heirs executed an extra-judicial settlement of estate with sale, whereby the disputed lot was allotted in its entirety to Joaquin.
On July 15, 1968, petitioner filed a suit against the heirs for annulment of the original 1938 sale, alleging a violation of the constitutional prohibition against aliens acquiring private land. The respondents, except for one who filed an answer, moved to dismiss the complaint on grounds of lack of cause of action (citing pari delicto and the current ownership by a citizen), laches, and acquisitive prescription. The Court of First Instance dismissed the complaint, sustaining the grounds of lack of cause of action and laches.

ISSUE

Whether the trial court correctly dismissed the complaint for annulment of the 1938 sale.

RULING

Yes, the Supreme Court affirmed the dismissal. The legal logic proceeds from the alteration of the underlying constitutional disability and the application of laches. First, while the original vendee, Tan Tai, was an alien disqualified from owning land under the 1935 Constitution, the property had subsequently been transferred to his son, Joaquin, a naturalized Filipino citizen. The constitutional prohibition aims to preserve land for Filipinos; this purpose is not thwarted but is fulfilled when the land is held by a qualified citizen. Therefore, there is no longer any public policy served in annulling the sale to return the land to the original vendor, as it is already in the hands of a constitutionally qualified owner.
Second, the doctrine of laches bars the petitioner’s claim. She sold the property in 1938 but waited until 1968—thirty years later—to seek annulment. This constitutes an unreasonable and unexplained delay in asserting a right, implying abandonment or neglect. By sleeping on her rights for such an extended period, during which the property’s ownership was consolidated in a qualified citizen, petitioner is estopped from challenging the sale. The combination of the removal of the constitutional impediment through Joaquin’s citizenship and the petitioner’s inaction justified the dismissal of the action.