GR 47491; (May, 1989) (Digest)
G.R. No. 47491 May 4, 1989
GALICANO GOLLOY, petitioner, vs. HONORABLE COURT OF APPEALS, JOSE VALDEZ, JR., CONSOLACION VALDEZ, LOURDES VALDEZ, SOLEDAD VALDEZ and BENNY MADRIAGA, respondents.
FACTS
Petitioner Galicano Golloy, the registered owner under TCT No. 45764, filed an action to quiet title against private respondents. The dispute arose when respondents, subdividing their adjacent land covered by TCT No. 8565, placed two monuments within the southwest portion of Golloy’s land. In pre-trial, the parties agreed to appoint a Bureau of Lands surveyor to relocate and determine the true boundaries. Surveyor Jovino Dauz’s report found an overlapping area, attributing it to a defect in the survey of Golloy’s land, which was surveyed and titled later than respondents’ land. The report concluded that respondents’ earlier-surveyed title should prevail. The trial court and the Court of Appeals ruled in favor of respondents based on this report.
ISSUE
The sole issue is who, between the two registered title holders, is entitled to the disputed overlapping portion of land.
RULING
The Supreme Court reversed the lower courts and ruled in favor of petitioner Golloy. The legal logic centered on the principle of laches, not merely the technical priority of survey and registration dates. The Court found that Golloy and his predecessor-in-interest had been in open, continuous, exclusive, and notorious possession of the entire parcel, including the overlapped area, in the concept of an owner for nearly fifty years—from the registration of his title in 1919 until the disturbance in 1966. In contrast, respondents and their predecessors never possessed or asserted any claim over the disputed portion during this entire period. The Court held that while a Torrens title is indefeasible, it does not protect a title holder who, through inaction and delay, sleeps on his rights. Respondents’ failure to assert any claim for almost five decades constituted laches, an equitable doctrine that bars stale claims. Consequently, equity demanded that the overlapped portion be reconveyed to Golloy, the possessor in good faith, to prevent a manifest injustice. The Court ordered the segregation of the disputed area and the issuance of a new title in Golloy’s favor.