G.R. No. 169898 ; October 27, 2006
SPOUSES ANITA AND HONORIO AGUIRRE, petitioners, vs. HEIRS OF LUCAS VILLANUEVA, respondents.

FACTS

The respondents, heirs of Lucas Villanueva, filed a complaint for annulment and recovery of ownership over a 140-square meter residential lot in Malay, Aklan. They claimed ownership by inheritance from their father, Lucas, who possessed the land under a 1947 tax declaration. They alleged that in 1997, the petitioners, spouses Aguirre, fenced the land without consent. The Aguirres defended their ownership, asserting that Anita inherited the property from her father, Eutiquiano Salazar, who acquired it from Ciriaco Tirol via a Deed of Exchange in 1971. They argued they had possessed the land openly and adversely since 1971, first fencing it in 1981 and with hollow blocks in 1985, without opposition from the Villanuevas.
The Regional Trial Court ruled in favor of the Villanuevas, declaring them the lawful owners and ordering the Aguirres to restore possession. The court found the Aguirres’ root of title defective, as Ciriaco Tirol’s ownership was not established, and held that their possession, starting only in 1971, was insufficient for acquisitive prescription. The Court of Appeals affirmed this decision.

ISSUE

Whether the petitioners have acquired ownership of the disputed property through ordinary acquisitive prescription and whether the respondents’ action is barred by laches.

RULING

The Supreme Court reversed the lower courts and ruled in favor of the petitioners, the spouses Aguirre. On the pivotal issue of prescription, the Court held that the petitioners acquired title through ordinary acquisitive prescription. Under the Civil Code, ownership of real property is acquired by ordinary prescription through possession for ten years, provided the possession is in good faith and with a just title. The Court found that the petitioners and their predecessor-in-interest had been in continuous, open, and peaceful possession of the land in the concept of an owner since the 1971 Deed of Exchange. This possession, which exceeded ten years, was in good faith as they believed in the validity of their title from the Deed. Consequently, they acquired ownership by ordinary prescription by 1981.
Furthermore, the Court ruled that the respondents’ action was barred by laches. Laches is the failure to assert a right for an unreasonable length of time, warranting a presumption of abandonment. The evidence showed that the respondents were aware the petitioners had fenced the property as early as 1981 but took no action to assert their claim until 1997—a delay of sixteen years. This unreasonable inaction, prejudicial to the petitioners who had developed the land, justified the application of the equitable doctrine of laches. Thus, the respondents’ claim was stale and could no longer be enforced.