GR 182673; (October, 2009) (Digest)
G.R. No. 182673 ; October 5, 2009
AQUALAB PHILIPPINES, INC., Petitioner, vs. HEIRS OF MARCELINO PAGOBO, et al., Respondents.
FACTS
The respondents, heirs of Juan Pagobo, filed a complaint for partition, annulment of documents, and reconveyance against Aqualab Philippines, Inc. over two subdivision lots (Lots 6727-Q and 6727-Y) originally part of a larger homestead (Lot 6727) granted to Juan Pagobo. The homestead patent was issued posthumously in 1969, leading to the issuance of OCT RO-2246. Prior to this, the mother lot had been subdivided. The disputed lots were subsequently sold by Pagobo’s heirs to Tarcela de Espina in 1970, and the titles eventually passed through several purchasers until acquired by Aqualab in 1988. The respondents claimed their peaceful possession since 1936 was disturbed only in 1991 and asserted that the sales by their predecessors were void for violating the five-year prohibition on alienation of homestead lands under the Public Land Act.
The Regional Trial Court dismissed the complaint, finding the respondents’ action barred by laches and prescription. The Court of Appeals reversed, ruling that an action for reconveyance based on a void contract is imprescriptible. The CA held the sales executed within the five-year prohibitory period were null and void ab initio, and thus the subsequent titles derived therefrom were also void.
ISSUE
Whether the action for reconveyance filed by the respondents is barred by prescription and laches.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the RTC’s dismissal. The Court held the action was indeed barred by prescription and laches. While an action for reconveyance based on a void contract is imprescriptible, this principle applies only when the plaintiff is in possession of the property. Here, the respondents alleged possession only until 1991, when Aqualab disturbed it. The complaint, filed in 1994, was an action for reconveyance based on an implied or constructive trust, which prescribes in ten years from the issuance of the title. The titles from which Aqualab’s ownership was derived were issued in 1970 (to Tarcela de Espina). The respondents’ action, filed 24 years later, was clearly time-barred.
Furthermore, the Court found laches applicable. The respondents and their predecessors slept on their rights for over two decades, allowing the properties to be transferred to innocent purchasers for value. Aqualab, as the current registered owner, was a purchaser in good faith, having relied on the clean titles on record. The long delay in asserting their claim, coupled with the prejudice caused to Aqualab who developed the land, militated against granting the respondents relief. The legal logic prioritizes the stability of registered titles and the principle that equity aids the vigilant, not those who slumber on their rights.