G.R. No. 182716; June 20, 2012
HEIRS OF JOSE MALIGASO, SR., namely, ANTONIO MALIGASO, CARMELO MALIGASO and JOSE MALIGASO, JR., Petitioners, vs. SPOUSES SIMON D. ENCINAS and ESPERANZA E. ENCINAS, Respondents.

FACTS

Respondents, the registered owners of Lot No. 3517 under TCT No. T-4773, filed an unlawful detainer complaint against petitioners, who occupied a 980-square-meter portion of the lot. The respondents acquired the lot in 1968 from Virginia Escurel, who purchased it from Maria Maligaso Ramos in 1965. Maria had obtained Original Certificate of Title No. 543 for the lot in 1929. After purchasing the property, the respondents issued demand letters to vacate in 1998. The petitioners refused, asserting ownership based on their father’s alleged successional rights to their grandparents’ estate and attacking the validity of the titles secured by Maria and the respondents.
The Municipal Trial Court (MTC) dismissed the complaint, adjudging possessory rights to the petitioners, finding their possession rooted in their father’s inheritance and suggesting a trust was created in his favor. It also ruled the respondents were barred by laches due to their 30-year inaction. The Regional Trial Court (RTC) affirmed the MTC’s dismissal. The Court of Appeals (CA) reversed these decisions, granting possession to the respondents.

ISSUE

Whether the Court of Appeals correctly reversed the lower courts and ruled in favor of the respondents in the unlawful detainer action.

RULING

Yes, the Supreme Court affirmed the CA’s decision. The core legal principle is that a Torrens title holder is entitled to possession, and the sole issue in an unlawful detainer case is the legality of possession stemming from the expiration of the petitioner’s right to hold. The respondents, as registered owners, established that the petitioners’ possession was by mere tolerance, which became unlawful upon the owners’ demand to vacate. The petitioners’ defenses, which challenged the validity of the respondents’ title and asserted ownership based on inheritance, were improper for the summary proceeding of unlawful detainer. Such claims of ownership or attacks on a Torrens certificate of title must be raised in a direct action, such as for reconveyance, not as a defense in an ejectment suit.
Furthermore, the defense of laches is unavailing against the registered owners. Laches cannot bar an action to recover possession based on a Torrens title where the possession is merely tolerated. The lawful owner’s right to demand return is imprescriptible as long as the possession is unauthorized. Conversely, the petitioners themselves may be guilty of laches for failing to assert their alleged hereditary claim for decades despite the title being registered in Maria’s name as early as 1929. Therefore, the respondents are entitled to possession.