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 inside the southwest portion of Golloy’s land. In pre-trial, the parties agreed to appoint a Bureau of Lands surveyor to relocate the boundaries. Surveyor Jovino B. Dauz reported an overlapping area, attributing the defect to Golloy’s later survey (1918) which did not conform to the earlier approved survey of respondents’ land (1913). The trial court, adhering to the surveyor’s report, ruled for respondents, a decision affirmed by the Court of Appeals.
The factual record established that Golloy and his predecessor-in-interest had been in open, continuous, and exclusive possession of the entire parcel, including the overlapped portion, for nearly fifty years—from the registration of his title on August 15, 1919, until the disturbance in February 1966. Conversely, respondents and their predecessor, Dominga Balanga, never possessed or asserted any claim over the disputed portion during that entire period.
ISSUE
The sole issue is who, between the two registered title holders, is entitled to the overlapped portion of land.
RULING
The Supreme Court reversed the lower courts and ruled in favor of petitioner Golloy. The legal logic rests on the equitable doctrine of laches, which bars a claim due to unreasonable delay in asserting it, prejudicing the adverse party. While the technical report favored respondents based on the earlier survey date, the Court emphasized that registration under the Torrens system does not protect a title holder who, through inaction, sleeps on his rights. Golloy’s undisturbed possession for almost five decades constituted a superior equitable right. Respondents’ predecessor, despite holding an earlier title, never took any step to possess or claim the area until 1966. This prolonged failure to assert ownership, while Golloy maintained possession, constitutes laches. The Court cited precedents (Caragay-Layno and Lola vs. Court of Appeals) where inaction for 20 and 32 years, respectively, barred recovery. Consequently, respondents are ordered to segregate the disputed portion and reconvey it to Golloy, with the Register of Deeds to issue a corresponding new title. The decision prioritizes equity and the reality of long-standing possession over a purely technical finding of survey priority.
