G.R. No. 150654 ; December 13, 2007
HEIRS OF ANACLETO B. NIETO, namely, SIXTA P. NIETO, EULALIO P. NIETO, GAUDENCIO P. NIETO, and CORAZON P. NIETO-IGNACIO, represented by EULALIO P. NIETO, Petitioners, vs. MUNICIPALITY OF MEYCAUAYAN, BULACAN, represented by MAYOR EDUARDO ALARILLA, Respondent.

FACTS

Anacleto Nieto was the registered owner of a parcel of land in Meycauayan, Bulacan, covered by TCT No. T-24.055 (M). Upon his death in 1993, his heirs (petitioners) discovered the owner’s duplicate certificate of title was in the possession of the Municipality of Meycauayan, which had been using the property as an extension of the public market since 1966 without paying rent or compensation. Petitioners made a formal demand for the return of the property and payment of rent in February 1994. Upon the Municipality’s refusal, they filed a complaint for recovery of possession and damages.
The Regional Trial Court (RTC) dismissed the complaint, finding that while the Municipality failed to prove its claim of donation, the action was barred by prescription and laches. The RTC reasoned that the imprescriptibility of an action to recover registered land applied only to the registered owner himself, Anacleto Nieto, and not to his heirs. The Court of Appeals dismissed the appeal on a procedural ground, leading petitioners to elevate the case to the Supreme Court.

ISSUE

The core issues were: (1) whether an action to recover possession of land registered under the Torrens System prescribes; (2) whether the defense of laches is applicable; and (3) whether the imprescriptibility of such an action can be invoked only by the registered owner to the exclusion of his heirs.

RULING

The Supreme Court ruled in favor of the petitioners, reversing the lower courts. On prescription, the Court held that an action to recover possession of registered land never prescribes. This is anchored on the principle of indefeasibility of a Torrens title, where no title in derogation of that of the registered owner can be acquired by prescription or adverse possession. The trial court erred in limiting this imprescriptibility solely to the registered owner in whose name the land is inscribed.
The Court clarified that the rule on imprescriptibility extends to the heirs of the registered owner. Hereditary successors step into the shoes of the decedent by operation of law; they are the continuation of the predecessor’s legal personality. Therefore, petitioners, as heirs, could invoke the same imprescriptible character of the action to recover the registered property.
Regarding laches, the Court found it inapplicable. Laches requires neglect for an unreasonable length of time to assert a right, leading to a presumption of abandonment. Here, the registered owner, Anacleto Nieto, had the right to bring an action at any time during his life, and his inaction did not prejudice his heirs. The heirs promptly acted upon discovering the missing title and the Municipality’s possession after Anacleto’s death. Their delay, if any, was adequately explained and did not constitute laches. The Court ordered the Municipality to vacate the property, pay accrued rentals, and return the owner’s duplicate certificate of title.