GR 113652; (August, 1995) (Digest)

G.R. No. 113652 August 14, 1995
VICTORIANO A. CORMERO, petitioner, vs. THE HONORABLE COURT OF APPEALS; HON. PEDRO S. ESPINA, Presiding Judge, RTC 8TH Judicial Region, Palo, Leyte, Branch 7, OCEANIC REAL ESTATE, INC., represented by its Corporate Secretary, REYNALDO LIM; and the REGISTER of DEEDS OF TACLOBAN CITY, respondents.

FACTS

Petitioner Victoriano A. Cormero sought to register a 1920 “Documento de Venta Absoluta” and an “Orden,” claiming they evidenced his inheritance of Lot 67 from his great grand aunt, Ambrocia Cormero. The Register of Deeds denied the application, citing the cancellation of the original title and questions on the documents’ authenticity. After the National Land Titles and Deeds Registration Administration reversed this denial, private respondent Oceanic Real Estate, Inc., the registered owner of the consolidated lot (which includes Lot 67) under TCT No. T-25197, filed a petition for prohibition and injunction. Oceanic alleged the documents were spurious and that it was in possession of the land, upon which a three-storey building stood.
The Regional Trial Court ruled in favor of Oceanic, permanently enjoining the registration. It found the deed of sale to be falsified and, alternatively, held that even assuming it was genuine, petitioner’s claim was barred by laches. The Court of Appeals affirmed this decision in toto.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s decision which denied petitioner’s application for registration of his documents of title on the ground of laches.

RULING

The Supreme Court denied the petition and affirmed the assailed decision. The Court applied the doctrine of laches, which is a failure or neglect, for an unreasonable and unexplained length of time, to do that which by exercising due diligence could or should have been done earlier. The legal logic is that equity aids the vigilant, not those who slumber on their rights.
The Court found petitioner’s inaction inexcusable. The right allegedly originated from a 1920 sale to Ambrocia Cormero, who died in 1922. The title was supposedly passed to petitioner’s father, who took no action for 60 years until his death in 1982. Petitioner himself only asserted the right in 1989. This 67-year delay, while the property was under the registered ownership and open possession of another, constituted laches. The Court emphasized that failure to assert a right for an extended period, especially when it prejudices the adverse party who has established rights over the property, results in the loss of that right through acquiescence. Consequently, petitioner was barred from claiming title over the disputed land.