GR L 79317; (June, 1988) (Digest)
G.R. No. L-79317 June 28, 1988
EMILIANO ALCOS, ROSARIO E. ALCOS, TERESA E. ALCOS, LYDIA E. ALCOS, HILARIO E. ALCOS and CATALINA ALCOS, petitioners, vs. INTERMEDIATE APPELLATE COURT, ATLAS CONSOLIDATED MINING & DEVELOPMENT CORPORATION, and BLAS P. CAVADA, SR., and Heirs of Natividad Noel, namely: CAROLINA CAVADA, PATRICIO N. CAVADA, BLAS N. CAVADA, JR., DARIO N. CAVADA, and JOSE N. CAVADA, respondents.
FACTS
Petitioners, heirs of Cristeta Emnace Alcos, filed an action for reconveyance of five parcels of land in Toledo City. They claimed ownership by inheritance from Cristeta, who died in 1968, and alleged that a 1950 Deed of Absolute Sale conveying the properties to respondent Blas P. Cavada, Sr. for P4,500.00 was a forgery. The Regional Trial Court ruled in favor of the petitioners, declaring the deed null and void due to forgery and ordering the respondents to vacate the land, pay substantial damages, and reimburse decades of unrealistically calculated rentals.
On appeal, the Intermediate Appellate Court reversed the RTC decision. It found the deed of sale valid, noting the notarization by Atty. Delfin Mercader and a series of letters and postal money orders from Cavada to Emiliano Alcos between 1950 and 1951, which evidenced the installment payments of the purchase price. The appellate court dismissed the complaint, prompting this petition for review.
ISSUE
The core issue is whether the petitioners’ action for reconveyance based on alleged forgery of the deed of sale is barred by laches.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision, primarily on the ground of laches. The Court clarified that while an action to declare a void contract inexistent does not prescribe, the equitable principle of laches can still bar the claim. Laches is the failure or neglect, for an unreasonable length of time, to assert a right, warranting the presumption that the party has abandoned it or acquiesced to the adverse claim.
In this case, the Court found the petitioners’ inaction inexcusable. The alleged sale occurred in 1950, and the petitioners only filed suit in 1975—twenty-five years later. During this prolonged period, respondent Cavada and later Atlas Consolidated Mining took open, continuous, and notorious possession of the land, transforming the raw agricultural property through significant investment and development. The petitioners, despite being aware of these activities, stood by without asserting their rights. To allow their claim after such a lengthy delay, during which the property’s value increased immensely due to the respondents’ efforts, would result in a grossly inequitable outcome. Thus, regardless of the technical arguments on prescription or forgery, the petitioners’ claim was deemed stale and barred by laches.