G.R. No. 157567 ; August 10, 2007
HEIRS OF MARCELA SALONGA BITUIN, Petitioners, vs. TEOFILO CAOLENG, SR., ET AL., Respondents.

FACTS

The case involves a dispute over three parcels of land in Guagua, Pampanga, originally owned by siblings Juan and Epifania Romero. Petitioners are the heirs of Juan Romero’s descendant, Marcela Salonga Bituin. Respondents are the heirs of Epifania Romero’s descendant, Agustin Caoleng. Petitioners filed a complaint for quieting of title and reconveyance, alleging that respondent Teofilo Caoleng fraudulently secured Original Certificates of Title (OCT Nos. 3398 and 3399) for two lots (Cad. Lot Nos. 3661 and 3449) in the name of Agustin Caoleng alone, excluding petitioners’ one-half pro-indiviso share as co-heirs. They also referenced an Extra-Judicial Settlement of Estate from 1983, which purportedly recognized Marcela Salonga’s share in Lot No. 3661.
The Regional Trial Court (RTC) ruled in favor of petitioners, declaring them co-owners of the disputed lots and ordering reconveyance. The Court of Appeals (CA) reversed the RTC, holding that petitioners’ action was a collateral attack on a Torrens title, which is prohibited, and that they were guilty of laches for inaction since the titles were issued in 1976.

ISSUE

Whether petitioners’ action for reconveyance and quieting of title constitutes a prohibited collateral attack on a Torrens title and is barred by laches.

RULING

The Supreme Court reversed the CA and reinstated the RTC decision. The Court held that an action for reconveyance based on fraud is not a collateral attack on a certificate of title but a direct challenge seeking its correction. A collateral attack occurs when, in another proceeding, the certificate’s validity is questioned without directly seeking its amendment or cancellation. Here, petitioners explicitly sought the cancellation of the OCTs and reconveyance of their share, making it a direct, permissible action.
On laches, the Court ruled it did not apply. Laches requires negligence or delay in asserting a right, causing prejudice to the adverse party. The Court found petitioners were not negligent. They discovered the fraud only after Marcela’s death in 1986 when they found the OCT and related documents. They filed the case in 1989, a reasonable period. Furthermore, the 1983 Extra-Judicial Settlement, wherein respondents themselves acknowledged Marcela’s share, estopped them from claiming exclusive ownership and negated any prejudice from delay. Thus, petitioners timely pursued their rightful claim as co-owners.