GR 50889; (February, 1990) (Digest)
G.R. No. 50889 February 21, 1990
MAXIMINO, TEODORA, LEODEGARIO, CELESTINA, SALVADOR, TIMOTEO, LORENZO, JOSE, JUANITA, CRECIDA, alias SIDANG, SILVINO, alias BINOY, 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. The vendors were Fernando Quilisadio (a legitimate child of the spouses), Rustica Quilisadio (grandchild), and Tranquilino Tasan (grandchild). They executed a deed of absolute sale for P800.00, representing that they had acquired the property by hereditary title. Conejos immediately took possession, declared the land for taxation, and paid taxes. In 1968, twenty-two years later, the other heirs of Catalino and Isabel, 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.
ISSUE
The primary issue is whether the petitioners’ action to recover the land is barred by laches, notwithstanding the land being registered under the Torrens system.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions, ruling that the action was barred by laches. The legal logic is that while the Torrens title is imprescriptible, the right to recover possession based on that title can be lost through the equitable doctrine of laches. Laches is the failure or neglect to assert a right for an unreasonable and unexplained length of time, warranting a presumption that the party entitled to assert it has abandoned or declined to assert it.
Here, the petitioners waited twenty-two years from the 1946 sale before filing suit. During this entire period, respondent Conejos was in open, continuous, exclusive, and notorious possession of the land, exercising acts of ownership such as paying taxes. The petitioners offered no credible explanation for this inordinate delay. Their claim of having only recently discovered the sale was deemed unconvincing given the long period of adverse possession. This unreasonable delay prejudiced Conejos, who relied on the finality of the transaction. Consequently, the petitioners were guilty of laches and lost their right to challenge the sale. Regarding respondent corporation H. Serafica & Sons, it was correctly impleaded as a proper party, being the lessee, to ensure complete adjudication of the controversy.