G.R. No. L-11754; April 29, 1960
SATURNINO D. VILLORIA, plaintiff-appellant, vs. HON. SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, ET AL., defendants-appellees.

FACTS

On June 26, 1923, plaintiff Saturnino D. Villoria purchased Lot No. 89, a Friar Land, from the Government, paying the first installment. For failure to pay subsequent installments, the Director of Lands unilaterally cancelled the sale certificate on April 5, 1935. Over two years later, on August 10, 1937, the same lot was purchased by Susana Villoria under Commonwealth Act No. 32 . On September 24, 1945, Nicanor, Edilberta, and Emiliana Villoria filed a joint petition with the Bureau of Lands claiming preferential right to purchase portions of the lot they occupied. The Director of Lands denied their petition on June 24, 1947, but the Secretary of Agriculture and Natural Resources reversed this decision on January 2, 1948, ordering subdivision and sale to the petitioners with refund to Susana Villoria. Susana Villoria’s subsequent judicial actions, including a petition to the Supreme Court (G.R. No. L-2169) and a civil case (No. R-601), were ultimately dismissed. On June 30, 1953, Saturnino D. Villoria, upon learning the lot was about to be subdivided and deeds of sale issued to the other Villorias, sent a telegram and a letter requesting suspension. On July 27, 1953, he filed the present action for injunction to restrain the defendants from subdividing the lot and executing deeds of conveyance. The trial court declared the unilateral cancellation of his sale contract null and void but dismissed the complaint on the grounds of prescription and/or laches.

ISSUE

Whether the plaintiff’s action is barred by laches.

RULING

Yes, the plaintiff’s action is barred by laches. The Supreme Court affirmed the trial court’s decision. While the unilateral cancellation of the sale contract by the Director of Lands on April 5, 1935, was illegal under the Friar Lands Act (Act No. 1120), which required judicial foreclosure for non-payment, the plaintiff first asserted his claim only on June 30, 1953, via telegram, and filed his complaint on July 27, 1953. This constituted a delay of over 18 years from the cancellation and about 15 years from the lot’s sale to Susana Villoria. The Court found all four elements of laches present: (1) conduct by the defendants (the cancellation and subsequent sale) giving rise to the complaint; (2) delay by the plaintiff in asserting his rights, despite having knowledge or notice of the defendants’ conduct and opportunity to sue; (3) lack of knowledge by the defendants that the plaintiff would assert his right; and (4) injury or prejudice to the defendants (specifically, Susana and the other Villorias who had undergone lengthy administrative and judicial proceedings and were in actual possession since 1937 or earlier) if relief were granted. The plaintiff’s prolonged inaction converted his claim into a stale demand, and granting relief would cause injustice to the parties who had acquired intervening rights. The decision appealed from was affirmed.