G.R. No. 84905 February 1, 2000
REGINO CLEOFAS and LUCIA DELA CRUZ, petitioners, vs. ST. PETER MEMORIAL PARK INC., et al., respondents.

FACTS

The controversy involves Lot No. 719 of the Piedad Estate. Petitioners, heirs of Antonio Cleofas, claimed ownership based on a 1909 Sales Certificate issued to their predecessor. After Antonio’s title was burned in 1933, petitioners discovered the lot was registered under respondent St. Peter Memorial Park. They filed a 1970 suit for annulment of title and recovery of possession. The trial court initially ruled for petitioners in 1973, declaring them rightful owners and ordering reconstitution of their title while nullifying the respondents’ titles.
Upon remand for new trial after a Supreme Court order, respondents presented evidence that Antonio Cleofas was actually the awardee of a different lot, Lot 640, not Lot 719. They further established a chain of title showing Antonio Cleofas had assigned his rights to Lot 719 to Aniceto Martin and Trino Narciso in 1921, leading to subsequent valid transfers culminating in respondent Memorial Park’s ownership. The trial court, however, reinstated its 1973 decision. The Court of Appeals reversed this, dismissing petitioners’ complaint, prompting this appeal.

ISSUE

Whether petitioners have a superior right of ownership over Lot No. 719, warranting the annulment of the respondents’ certificates of title and recovery of possession.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic rests on the validity of the documented chain of title and the application of evidentiary presumptions and laches. Respondents conclusively established through public documents that Antonio Cleofas assigned his rights to Lot 719 to Martin and Narciso in 1921 via a notarized deed. This assignment was subsequently confirmed by a 1929 Deed of Conveyance from the Director of Lands to the assignees. These notarized documents carry the presumption of regularity, which petitioners failed to rebut with clear and convincing evidence.
Furthermore, petitioners were barred by laches. They admitted possession ceased in 1945, yet they filed their suit only in 1970. This unreasonable delay of 25 years in asserting their claim, while respondents and their predecessors exercised ownership, constitutes abandonment of their right. Petitioners’ inaction precludes recovery, as laches operates to prevent the enforcement of a stale claim where a party’s neglect to assert a right has misled another. Thus, respondents’ ownership, derived from a regular sequence of transactions, was upheld.