G.R. No. 157852 ; December 15, 2010
HEIRS OF DOMINGO VALIENTES, Petitioners, vs. Hon. REINERIO (Abraham) B. RAMAS, Acting Presiding Judge, RTC, Branch 29, 9th Judicial Region, San Miguel, Zamboanga del Sur and Vilma V. Minor, Respondents.

FACTS

Petitioners, heirs of Domingo Valientes, filed a complaint for cancellation of title, reconveyance, and damages against respondent Vilma V. Minor. They alleged that their predecessor mortgaged the land to the spouses Belen in 1939. The Valientes family failed to retrieve it, and the Belens later obtained a title through a forged deed of sale. In 1970, Valientes’ children annotated an adverse claim on the title. Upon the Belens’ death, their heirs executed an extrajudicial settlement selling the property to Minor. In 1979, Minor filed a petition (SPL Case No. 1861) to cancel the adverse claim, which the RTC granted in 2000. Meanwhile, in 1998, petitioners filed their own complaint (Civil Case No. 98-021). Minor moved to dismiss this 1998 case on grounds of forum shopping and litis pendentia. The RTC initially denied the motion but, upon reconsideration, dismissed the case for forum shopping.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in dismissing the petitioners’ complaint on the grounds of prescription and laches, despite the respondent not having appealed the RTC’s order of dismissal which was based solely on forum shopping.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is twofold. First, the Court of Appeals has the authority to consider unassigned errors, such as prescription and laches, if their consideration is necessary for a complete and just resolution of the case. This discretionary review power is aimed at achieving substantial justice and avoiding unnecessary delays. Second, on the substantive merits, the Court found the action barred. The petitioners’ cause of action, while captioned as one for cancellation and reconveyance, was in substance an action to annul a voidable title allegedly obtained through a forged deed of sale in the 1950s. Such an action prescribes in ten years from the issuance of the title. The title was issued decades before the 1998 complaint was filed. Furthermore, the petitioners’ long inaction—failing to assert their claim promptly despite knowledge of the sale and the issuance of a new title—constituted laches. Their annotation of an adverse claim in 1970 demonstrated awareness, yet they waited until 1998 to file suit, allowing the property to be transferred to an innocent purchaser for value. Thus, the action was correctly dismissed.