G.R. No. 50889 February 21, 1990
MAXIMINO, TEODORA, LEODEGARIO, CELESTINA, SALVADOR, TIMOTEO, LORENZO, JOSE, JUANITA, CRECIDA, SILVINO, NESTORIO and ADELINA, all surnamed QUILISADIO, petitioners, vs. THE HONORABLE COURT OF APPEALS, PRIMO CONEJOS and H. SERAFICA & SONS CORPORATION, respondents.

FACTS

The land in dispute, originally owned by the deceased spouses Catalino Quilisadio and Isabel Dagar, was sold on December 24, 1946, to respondent Primo Conejos by Fernando Quilisadio (a legitimate child of the spouses), Rustica Quilisadio (a granddaughter), and Tranquilino Tasan (a grandson). The vendors executed a deed of absolute sale, representing that they had acquired the property by hereditary title. Conejos immediately took possession, declared the land for taxation, paid taxes, and enjoyed it to the exclusion of others. In 1968, twenty-two years after the sale, the other heirs of the original spouses, the petitioners, filed a complaint for recovery of ownership and possession. They alleged the sale was made without their knowledge and involved only undivided interests, and they sought to exercise legal redemption. They later amended the complaint to include H. Serafica & Sons Corporation as a party-defendant, as it had leased a portion of the land from Conejos.

ISSUE

The primary issue is whether the petitioners’ action to recover the land is barred by laches, given their failure to assert their claim for over two decades after the sale and Conejos’s open possession.

RULING

The Supreme Court denied the petition and affirmed the decisions of the lower courts, ruling that the petitioners were guilty of laches. The legal logic is that while the registered land could not be acquired by ordinary acquisitive prescription due to its Torrens title, the equitable doctrine of laches operates independently. Laches is the failure or neglect, for an unreasonable length of time, to assert a right, warranting a presumption that the party entitled has abandoned it or declined to assert it. Here, Conejos purchased the property in 1946 and exercised acts of ownership openly, continuously, and exclusively for twenty-two years before the suit was filed. The petitioners offered no valid explanation for their prolonged inaction. Their claim of recent discovery of the sale was deemed unconvincing, as the possession and acts of ownership by Conejos were public and should have put them on inquiry. Consequently, their right to challenge the sale was deemed lost by laches. Regarding the inclusion of the corporate respondent, the Court held it was a proper, though not indispensable, party for complete adjudication of the controversy, as its leasehold interest was derivative from Conejos’s title.