G.R. No. 76148 December 20, 1989
ELISEO CARO, CARLOS CARO, BENITO CARO, CARMEN CARO BATAYOLA AND LORENZO CARO, petitioners, vs. HON. COURT OF APPEALS, SERAFIN V. RONZALES, JOSE RONZALES, JR. AND GEMME RONZALES, respondents.

FACTS

The petitioners, heirs of Epifanio Caro, sought the cancellation of Original Certificate of Title No. 0-6836 issued in 1970 in the names of the private respondents (the Ronzaleses) and the reconveyance of a 260-square-meter parcel of land. They claimed this lot was included in a larger parcel purchased by Epifanio from Simeon Gallego in 1948. The respondents asserted ownership derived from their predecessor, Pascuala Lacson, and evidenced by the Torrens title issued after cadastral proceedings. During the cadastral survey, Epifanio Caro filed an answer only for his consolidated property, designated Lot 54, while the mother of respondent Jose Ronzales, Jr. filed an answer for the adjacent Lot 55, which is the disputed land. No other claims were filed for Lot 55, leading to the issuance of title to the respondents.
The trial court dismissed the complaint for reconveyance, ruling in favor of the respondents on grounds of estoppel, absence of fraud in registration, and prescription. The Court of Appeals affirmed this decision. The Supreme Court reviewed the case, focusing on whether the action had prescribed, whether fraud attended the title’s issuance, and whether Epifanio Caro was in estoppel.

ISSUE

The primary issues were: (1) whether the action for reconveyance had prescribed; (2) whether fraud attended the issuance of the respondents’ certificate of title; and (3) whether the petitioner’s predecessor-in-interest was in estoppel.

RULING

The Supreme Court denied the petition and affirmed the appellate court’s decision, subject to a modification regarding prescription. The Court clarified that an action for reconveyance based on an implied or constructive trust, alleging fraud, prescribes in ten years from the issuance of the title. Since the title was issued in 1970 and the complaint was filed in 1975, the action had not prescribed. However, the Court upheld the dismissal on the grounds of estoppel and absence of fraud.
On the issue of fraud, the Court found no evidence that the respondents employed fraud in securing their title. The respondents and their predecessors had openly possessed the land long before World War II. Epifanio Caro was aware of this possession and the separate identity of the lot, as evidenced by tax declarations showing Pascuala Lacson, not him, as the eastern adjacent owner. His failure to assert a claim over Lot 55 during the cadastral proceedings, despite knowledge of the survey and his opportunity to file an answer, negated any allegation of concealment or fraud by the respondents.
The Court firmly applied the principle of estoppel. Epifanio Caro’s negligence and inaction estopped his heirs from challenging the title. He received a survey plan in 1963 but did not scrutinize it due to his lack of formal education. He relied solely on his own knowledge when purchasing the land and did not verify the boundaries against official documents. Most critically, during the cadastral survey, he filed an answer only for Lot 54 and took no action regarding Lot 55, despite being aware of the proceedings. His belated claim, filed only after the respondents obtained their indefeasible title, was barred by his own laches and failure to exercise due diligence in protecting his alleged interest.