GR 132677; (October, 2000) (Digest)
G.R. No. 132677 ; October 20, 2000
ISABELA COLLEGES, INC., petitioner, vs. THE HEIRS OF NIEVES TOLENTINO-RIVERA, ET AL., respondents.
FACTS
Nieves Tolentino-Rivera was the registered owner of a parcel of land under OCT No. P-216. On August 15, 1949, she and her husband, Pablo Rivera, executed a deed of sale conveying four hectares of this land to petitioner Isabela Colleges, Inc. The deed was signed by both spouses and duly notarized. Petitioner immediately took possession, using the land as its school campus, and eventually secured TCT No. 45890 in its name in 1970. Decades later, in 1991, Nieves filed a complaint against petitioner, alleging the 1949 sale was void. She claimed the land was her paraphernal property and her signature on the deed was forged, executed without her knowledge and consent. She sought to nullify the sale, cancel petitioner’s title, and recover ownership and possession.
ISSUE
The primary issues were: (1) whether the subject land was paraphernal property of Nieves; (2) whether her signature on the 1949 deed of sale was forged; and (3) whether her action was barred by prescription and laches.
RULING
The Supreme Court ruled in favor of Isabela Colleges, Inc., dismissing the complaint. On the first issue, the Court found the land was conjugal, not paraphernal. The property was acquired through a sales patent application filed during the marriage. Under the Public Land Act ( C.A. No. 141 ), a sales patent granted to a married woman inures to the conjugal partnership, unless it is proven the property was acquired with her exclusive funds. Nieves failed to provide such proof. On the second issue, the claim of forgery failed. Nieves initially requested an NBI examination but withdrew it, and she offered no clear evidence to substantiate the allegation. Her bare denial could not overcome the presumption of regularity accorded to the notarized deed.
Most decisively, the action was barred by laches. Nieves waited 42 years from the 1949 sale to file her suit. During this prolonged period, petitioner openly, continuously, and exclusively possessed the land, constructed school buildings, and declared it for taxation. Nieves took no action to contest the sale despite these obvious acts of ownership. Her silence and inaction, coupled with petitioner’s good faith and the significant change in position over decades, constituted laches. Equity demands that rights be asserted promptly; one cannot sleep on one’s rights to the prejudice of another who acted in good faith. The Court emphasized that even a voidable title can become indefeasible through laches.