GR 152866; (October, 2010) (Digest)
G.R. No. 152866; October 6, 2010
THE HEIRS OF ROMANA SAVES, et al., Petitioners, vs. THE HEIRS OF ESCOLASTICO SAVES, et al., and ENRIQUETA CHAVES-ABELLA, Respondents.
FACTS
Lot No. 382 was originally adjudicated in 1921 to the siblings Benedicta, Escolastico, Romana, Rafaela, Januaria, and Maximo Saves, each owning an undivided 1/6 share. Between 1941 and 1947, the heirs of these siblings sold their respective shares to Gaudencia Valencia through several deeds of sale. Consequently, Valencia obtained Transfer Certificate of Title (TCT) No. 148 in her name. In 1961, Valencia sold the entire lot to respondent Enriqueta Chaves-Abella, who was issued TCT No. 110.
In 1981, petitioners, claiming to be heirs of the original Saves siblings, filed a complaint for reconveyance, partition, and damages. They alleged the sales to Valencia were fraudulent and that the subsequent sale to Abella was fictitious. The Regional Trial Court (RTC) ruled in favor of petitioners, declaring the deeds of sale null and void and ordering reconveyance.
ISSUE
Whether petitioners’ action for reconveyance is barred by laches.
RULING
Yes, the action is barred by laches. The Supreme Court affirmed the Court of Appeals’ reversal of the RTC decision. Laches is the 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, warranting a presumption that the party entitled to assert it has abandoned or declined to assert it.
The Court found petitioners inexcusably negligent in asserting their rights. The sales to Valencia occurred in the 1940s, and title was issued in her name in 1949. Abella acquired the property in 1961. Petitioners, however, filed their suit only in 1981, after a delay of over three decades from Valencia’s registration and two decades from Abella’s purchase. This prolonged inaction, without valid justification, prejudiced respondent Abella, who was an innocent purchaser for value. The Torrens system aims to ensure stability of land titles, and allowing such a stale claim would undermine this principle. Equity thus militates against petitioners, as laches has effectively extinguished their right to recover the property.