GR L L 27088; (July 1975) (Digest)
G.R. No. L-27088 July 31, 1975
HEIRS OF BATIOG LACAMEN, petitioners-appellants, vs. HEIRS OF LARUAN, respondents-appellants.
FACTS
On January 28, 1928, Laruan executed a deed of sale in favor of Batiog Lacamen, conveying a parcel of land in La Trinidad, Benguet, for P300.00. The deed was notarized, and Lacamen immediately took possession, introduced improvements, and paid taxes. Upon Lacamen’s death in 1942, his heirs continued possession and tax payments. In 1957, the heirs discovered that Laruan’s heirs had procured a new owner’s copy of the original certificate of title by alleging its loss and subsequently caused the transfer of the title to their names. The heirs of Lacamen demanded reconveyance and, upon refusal, filed an action in the Court of First Instance of Baguio to declare them as owners and to cancel the new title issued to Laruan’s heirs. The trial court and the Court of Appeals ruled against Lacamen’s heirs, declaring the 1928 sale null and void for lack of approval by the Director of the Bureau of Non-Christian Tribes, as required by law for transactions involving illiterate non-Christians.
ISSUE
Whether the heirs of Batiog Lacamen have validly acquired ownership over the disputed land despite the initial nullity of the sale due to lack of official approval.
RULING
The Supreme Court reversed the lower courts and ruled in favor of Lacamen’s heirs. While the legal requirement for approval rendered the 1928 sale voidable, the doctrine of laches barred Laruan’s heirs from asserting their claim. The Court emphasized that laches is neglect or omission to assert a right over a length of time, causing prejudice to the adverse party. Here, Laruan and his heirs took no action to contest the sale or recover possession for nearly thirty years, from 1928 until after Lacamen’s death and continuous possession by his heirs. During this prolonged period, Lacamen and his heirs invested in the land, maintained open and peaceful possession, and paid taxes, while Laruan’s heirs remained silent. This inaction, coupled with the change in conditions and the prejudice suffered by Lacamen’s heirs who treated the land as their own, constituted laches. The Court held that equity must intervene to prevent injustice, as Laruan’s heirs slept on their rights and only sought to assert them after a long delay, motivated by greed. Consequently, the heirs of Lacamen acquired a superior equitable right to the land, and the title issued to Laruan’s heirs was ordered cancelled.