GR L 80006; (September, 1988) (Digest)
G.R. No. L-80006 September 21, 1988
APOLONIA BAUTISTA, substituted by her heirs, petitioners, vs. HONORABLE COURT OF APPEALS, SPOUSES SALUD SEBASTIAN AND NICANOR VICTORIA, ET AL., respondents.
FACTS
Petitioner Apolonia Bautista, the sister of the deceased Geminiano Bautista, filed a complaint for reconveyance and/or quieting of title over several fishpond properties. She claimed ownership by inheritance from her brother, who was married to Ana Gerardo. The properties in dispute consisted of Ana’s alleged paraphernal properties (Parcels 2 and 5) and properties acquired during her marriage to Geminiano (Parcels 1, 3, and 4). Upon Geminiano’s death in 1933, Ana instituted intestate proceedings. An amicable settlement was reached wherein Ana bought out the claims of Geminiano’s heirs, including Apolonia. The court subsequently issued an order declaring Ana as the sole heir of Geminiano. Relying on this order, the titles to the conjugally acquired properties were eventually consolidated in Ana’s name. Decades later, Ana sold all the disputed properties to various respondents.
ISSUE
The primary issue is whether Apolonia Bautista’s action for reconveyance is barred by res judicata and prescription.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals’ dismissal of the complaint. The Court held that the doctrine of res judicata squarely applies. The prior intestate proceeding (Civil Case No. 4655) involving Geminiano’s estate, which culminated in a court order declaring Ana as the sole heir, constitutes a final judgment on the merits by a court of competent jurisdiction. This judgment is conclusive not only on the matters actually adjudged but also on any other matter that could have been raised therein regarding the ownership and distribution of the estate properties. Apolonia, having participated in that settlement, is bound by its outcome and cannot relitigate the issue of ownership decades later.
Furthermore, the action is barred by prescription and laches. The cause of action accrued upon Geminiano’s death in 1933, yet the complaint was filed only in 1973, well beyond the ten-year prescriptive period for recovering title to real property. Apolonia’s unreasonable and unexplained delay of over forty years, during which the respondents and their predecessors-in-interest possessed the lands, paid taxes, and made improvements, constitutes laches. Courts cannot countenance a party who sleeps on her rights, only to assert them after an inordinate lapse of time when the value of the property has increased, to the prejudice of innocent purchasers for value.