GR L 35171; (June, 1983) (Digest)
G.R. No. L-35171. June 24, 1983.
FRANCISCO DE LA ROSA, petitioner, vs. ALEJANDRO ESPIRITU, FEDERICO ESPIRITU, DOLORES ESPIRITU, MARGARITA STA. TERESA, TOMAS STA. TERESA and THE COURT OF APPEALS, respondents.
FACTS
The property in dispute is a 1.6198-hectare agricultural land originally owned by Remigio Sta. Teresa. Upon his death, it was inherited by his children Vicente, Gliceria, and Tomas. Vicente and Gliceria died, leaving their shares to their respective descendants, the Espiritu siblings and Margarita Sta. Teresa, who all co-owned the land with Tomas. In 1929, Tomas sold the entire property via a pacto de retro sale, representing himself as the sole owner. The buyers consolidated ownership in 1935 after Tomas failed to redeem it and subsequently sold the land to Francisco de la Rosa. In 1935, de la Rosa won a forcible entry case against Tomas, gaining a final judgment for possession. In 1965, after registration proceedings where the other co-owners participated but failed to timely oppose, de la Rosa obtained an Original Certificate of Title.
In 1961, the other co-owners filed an action to annul the 1929 sale, claiming Tomas had no authority to sell their shares. The trial court declared the co-ownership persisted, awarding two-thirds to the co-owners and one-third to de la Rosa as Tomas’s transferee. The Court of Appeals affirmed. De la Rosa appealed to the Supreme Court, arguing his Torrens title was conclusive.
ISSUE
Whether the co-owners’ action to annul the sale and recover their shares is barred, and whether de la Rosa’s registered title prevails.
RULING
The Supreme Court reversed the Court of Appeals and adjudicated the entire land to petitioner Francisco de la Rosa. The legal logic rests on the principles of laches and the conclusiveness of a Torrens title. The co-owners’ delay of 26 years from the 1935 consolidation of ownership before filing their suit in 1961 constituted laches, prejudicing de la Rosa who acquired rights in due course. Furthermore, the land registration proceeding, which resulted in a decree and Original Certificate of Title in de la Rosa’s name, was an in rem action. The respondents, though aware, failed to effectively oppose it, and their Petition for Relief was denied as out of time. A Torrens title issued after judicial proceedings is absolute and conclusive. The respondents’ attempt to litigate ownership in a separate ordinary action, instead of challenging the registration decree directly, cannot override the indefeasibility of de la Rosa’s title. The Court held it would be highly unfair to deprive de la Rosa of his ownership based on a procedural technicality, emphasizing the paramount importance of the stability conferred by the Torrens system.
