G.R. No. 200558 July 1, 2015
CONSUELO V. PANGASINAN and ANNABELLA V. BORROMEO, Petitioners, vs. CRISTINA DISONGLO-ALMAZORA, RENILDA ALMAZORA-CASUBUAN, RODOLFO CASUBUAN, SUSANA ALMAZORA-MENDIOLA, CARLOS MENDIOLA, CECILIO ALMAZORA and NENITA ALMAZORA, Respondents.

FACTS

The subject property is a parcel of land in Biñan, Laguna, originally registered in the name of Aquilina Martinez. After World War II, Aquilina and her grandmother Leoncia Almendral borrowed money from their relative Conrado Almazora to rebuild their ruined house in Manila. In return, Leoncia entrusted the owner’s duplicate copy of the title (TCT No. T-18729) to Conrado for safekeeping. Conrado and his family thereafter remained on the property. Aquilina died in 1949, and the title was transferred to her sole heir, Aurora Morales-Vivar. Conrado died in 1972. In 1994, Aurora learned from Conrado’s widow, Cristina, that the title had been transferred to Conrado and the property sold to Fullway Development Corporation for P4,000,000.00. Aurora demanded delivery of the payment, but it was unheeded. On May 9, 1996, Aurora and her husband filed a complaint for damages against Conrado’s heirs (respondents), alleging the title was merely held in trust and the sale was unauthorized. Respondents countered that the property was properly transferred to Conrado via a 1949 “Adjudication and Absolute Sale” document signed by Aurora and her husband, and that the action was barred by prescription and laches. The Regional Trial Court dismissed the complaint, finding Aurora failed to prove her right and was guilty of laches. The Court of Appeals affirmed, ruling that Aurora slept on her rights for over 50 years and that the action, being based on an implied trust, prescribed in 10 years from the 1965 registration in Conrado’s name. Petitioners, Aurora’s heirs, elevated the case via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaint on the grounds of laches and prescription.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The Court held that petitioners are barred by laches. Laches is the failure to assert a right for an unreasonable length of time, warranting a presumption of abandonment. The records show Aurora knew Conrado possessed the title since 1945, yet she took no judicial action to recover it or assert ownership until 1996, a delay of over 50 years. This neglect constitutes laches, as equity will not aid a party who sleeps on their rights. Furthermore, the action had prescribed. The claim, being one to recover property obtained through fraud giving rise to an implied trust under Article 1456 of the Civil Code, prescribes in 10 years pursuant to Article 1144. The prescriptive period began on June 17, 1965, when the property was registered in Conrado’s name. Aurora had until June 17, 1975, to file suit. The complaint filed in 1996 was clearly beyond the prescriptive period. The Court also noted that the petition raised factual questions, which are generally not reviewable under a Rule 45 petition, but it nonetheless re-evaluated the records in the interest of substantial justice and found no reason to overturn the lower courts’ findings.