G.R. No. 103476 November 18, 1999
CODIDI MATA, et al., petitioners, vs. COURT OF APPEALS and HEIRS OF CLARO L. LAURETA, respondents.

FACTS

The case involves a homestead lot originally granted to spouses Marcos and Codidi Mata, members of a non-Christian cultural minority. In 1945, Marcos Mata sold the lot to Claro Laureta. A subsequent sale of the same property to Fermin Caram, Jr. in 1947 led to litigation (Civil Case No. 3083). The Court of First Instance in 1964 upheld the first sale to Laureta, declaring the second sale void, and ordered Laureta to secure the approval of the Secretary of Agriculture and Natural Resources for the deed of sale. This decision, affirmed by the Supreme Court, became final in 1982. In 1979, the Matas filed a separate action (Civil Case No. 1071) to recover the property, arguing the sale to Laureta was unenforceable due to lack of the required approval. The Supreme Court, in G.R. No. 72194 (1990), ruled that the judgment in Civil Case No. 3083 was not time-barred and could be executed.
Following this, the requisite approval for the 1945 deed was obtained from the Minister of Natural Resources in 1984, and a transfer certificate of title was issued to Laureta in 1985. Believing they could still exercise a right to repurchase under the Public Land Act, the heirs of Marcos Mata filed a new action in 1990 (Civil Case No. 2468) for legal redemption, reconveyance, and consignation. The Lauretas sought to enjoin this proceeding, leading to the present petition.

ISSUE

Whether the petitioners’ action to enforce their right to repurchase the homestead under Section 119 of the Public Land Act had already prescribed.

RULING

Yes, the right to repurchase had prescribed. The Court affirmed the Court of Appeals’ decision permanently enjoining the trial court from proceeding with Civil Case No. 2468. The legal logic is anchored on the nature and computation of the prescriptive period for the right of legal redemption (repurchase) granted to homesteaders or their heirs under Section 119 of Commonwealth Act No. 141 . This right must be exercised within five years from the date of the conveyance. The Court clarified that the crucial date is the execution of the sale, not the subsequent approval by the Secretary (now Minister) of Natural Resources, which is merely a confirmatory act.
The conveyance from Mata to Laureta occurred in 1945. Therefore, the five-year period to repurchase commenced in 1945 and expired in 1950. The petitioners filed their action for reconveyance only in 1990, which was four decades too late. The Court rejected the petitioners’ argument that the finality of the 1990 Supreme Court decision in G.R. No. 72194 (which dealt solely with the timeliness of executing the 1964 judgment) gave them a new period to repurchase. That prior case resolved a distinct issue on the execution of a final judgment and did not revive or create a new repurchase period. Since the records conclusively showed the action was filed long after the prescriptive period lapsed, a full trial was unnecessary. The Court emphasized the public policy interest in ending litigation, stating that judgments must become final to ensure effective justice administration.