GR 77744; (March, 1992) (Digest)
G.R. No. 77744 March 6, 1992
TEODORA CLAVERIAS, petitioner, vs. ADORACION QUINGCO, ERNESTO TONGSON and THE HONORABLE COURT OF APPEALS, respondents.
FACTS
Petitioner Teodora Claverias filed an action for annulment of title and reconveyance with damages involving Lot No. 737 of the Himamaylan Cadastre. She alleged that the lot, originally registered in her name and her brother Federico’s, was fraudulently reconstituted and later cancelled by respondent Adoracion Quingco, who obtained a new title in her own name. Quingco then executed a simulated deed of sale in favor of respondent Ernesto Tongson, who subsequently evicted petitioner from the land. Private respondents countered that the lot was sold twice by petitioner and her mother Sinforosa Flores to Venancia Alarcon de Quingco (Adoracion’s mother) in 1922 and 1930. After Venancia’s death, the lot was adjudicated to Adoracion Quingco in a testate proceeding, who later sold it to Tongson. The trial court dismissed the complaint, finding the sales valid and that the action was barred by prescription and laches, and that Tongson was a buyer in good faith. The Court of Appeals affirmed this decision.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s dismissal of the complaint on the grounds of prescription and laches.
RULING
The Supreme Court sustained the decision of the Court of Appeals. The Court held that the petitioner’s cause of action was barred by laches. The Court found that the petitioner and her mother had executed two deeds of absolute sale over the property in 1922 and 1930. The petitioner failed to assert her claim for an unreasonable length of time—from 1930 until she filed an action in 1959, and again from 1959 until the filing of the present case in 1972. During this period, the property had been transferred to an innocent purchaser for value (Tongson). The Court emphasized that laches is based on equity and the inequity of permitting a claim to be enforced after a long delay during which conditions have changed. The Court also noted that an action based on an implied trust, which petitioner alternatively claimed, prescribes in ten years from its repudiation. Thus, due to the equitable principle of laches, the petitioner’s action could no longer prosper.