G.R. No. 205711 , May 30, 2016
Pedro De Leon, Petitioner, vs. Nenita De Leon-Reyes, Jesus Reyes, Myeth Reyes and Jenneth Reyes, Respondents.

FACTS

Petitioner Pedro de Leon and respondent Nenita de Leon-Reyes are siblings. Their father, Alejandro de Leon, possessed two parcels of public land. Between 1995 and 1996, free patents were granted, and Original Certificates of Title (OCTs) were issued in the names of Nenita and her family. Pedro filed a protest with the DENR, alleging fraud, but it was dismissed. He did not appeal this dismissal. Subsequently, Nenita’s family filed an action for Recovery of Possession and Damages against Pedro (Civil Case No. 02-08). Pedro filed a separate action for Reconveyance of Title and Damages (Civil Case No. 02-20). The RTC consolidated the cases.
The RTC found the transfer of rights from Alejandro to Nenita and the subsequent free patents valid, as Pedro failed to substantiate his claims of forgery, notably by not formally offering his documentary evidence. However, the RTC ruled in Pedro’s favor on the issue of possession, applying the principle of laches. It held that Nenita’s inaction for over 32 years, despite Pedro’s open possession and introduction of improvements, barred her from recovering the property. The Court of Appeals reversed this decision.

ISSUE

Whether the Court of Appeals correctly reversed the RTC’s application of laches and upheld the validity of the titles held by Nenita and her family.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the CA’s ruling, emphasizing the indefeasibility of a Torrens title issued under a free patent one year after its issuance. Laches cannot be invoked to defeat the registered owners’ right to recover possession when the action was filed within the prescriptive period for a real action, which is thirty years. Nenita’s family filed their complaint for recovery of possession in 2002, well within the 30-year period from the issuance of the OCTs in 1995-1996.
Furthermore, the Court clarified the nature of Pedro’s action. By admitting that the lands were originally public domain and by seeking the cancellation of the patents and titles, his suit was effectively an action for reversion, which can only be instituted by the Solicitor General on behalf of the State. As a private individual, Pedro had no legal standing to file such an action. His proper remedy, if he believed the patents were obtained by fraud, was an action for reconveyance based on an implied trust, which prescribes in ten years. However, his failure to timely pursue this, coupled with his inability to present sufficient evidence to prove fraud, rendered his claim untenable. The titles of Nenita and her family, being regular on their face, must be respected.