G.R. No. 214540. July 28, 2021.
WENCESLAO EBANCUEL (NOW DECEASED), SUBSTITUTED BY HIS HEIRS, NAMELY: ADORACION EBANCUEL, MELITA EBANCUEL, ALBERT EBANCUEL, ROWENA EBANCUEL, AILYN EBANCUEL, AND WILLIAM EBANCUEL, PETITIONERS, VS. ROMULO ACIERTO, SEGUNDINO ACIERTO, BENJAMIN BARNACHIA, FELIZA BARNACHIA, MOISES BARNACHIA, ROMEO BARNACHIA, FEDERICO CANIAS, FELICIDAD ECLARINAL, DR. HONORIO A. EDAÑO, INECITA EDUCALANE, LOLITA EDUCALANE, TRINIDAD ECALDRE, LARRY ACIERTO (AS PER AMENDED ANSWER INSTEAD OF GUIDO ELAGO), MANUEL ECLEVIA, SR., HERMINIA ENCISO, ESPIRIDION MAGAYANO, CANDELARIA MAGAYANO, CONCEPCION REALIZO, AND DOMINADOR REALIZO, RESPONDENTS.

FACTS

Buenaventura Ebancuel was the registered owner of a two-hectare parcel of land in Masinloc, Zambales, covered by Certificate of Title No. 97. He died in 1948, leaving his son, petitioner Wenceslao Ebancuel, orphaned. Wenceslao lived with relatives in Olongapo City and was unaware of the property. In 1974, he discovered the property’s existence and title while searching records at the Register of Deeds of Zambales. He paid the inheritance and real property taxes, including arrears. In 1981, he visited the property and found respondents occupying it. After a failed barangay settlement, Wenceslao filed a complaint for recovery of possession and damages on May 17, 1984, which was dismissed without prejudice on October 8, 1986, for lack of interest to prosecute. On December 1, 1997, he filed the instant complaint for accion publiciana. Wenceslao died on September 12, 2001, and was substituted by his heirs (petitioners), with the title transferred to his widow, Adoracion Ebancuel. Respondents claimed they purchased the property from Buenaventura between 1940 and 1945 and had been in possession for over 30 years. The Regional Trial Court dismissed the case on the ground of laches, declaring respondents as absolute owners and possessors. The Court of Appeals affirmed the dismissal, finding Wenceslao’s actions barred by laches due to delays in asserting his rights.

ISSUE

Who is entitled to possession of the subject property?

RULING

The Supreme Court granted the petition and reversed the decisions of the lower courts. The Court ruled that the registered owner’s right to recover possession of property is imprescriptible and cannot be barred by laches. Wenceslao Ebancuel, and subsequently his heirs, were the registered owners of the property, as evidenced by Transfer Certificate of Title No. T-20033 and later TCT No. T-55599. The Court held that laches, being an equitable doctrine, cannot be invoked to defeat the registered owner’s imprescriptible right to eject any person illegally occupying the property. The delay alleged by respondents was not unreasonable, and petitioners never abandoned their right. The Court emphasized that the certificate of title is conclusive evidence of ownership, and no title to registered land can be acquired by prescription or adverse possession against the registered owner. The case was remanded to the trial court to determine the issue of possession.