The Supreme Court has denied the petition of the Heirs of Santos, Simeon, Candido, and Rosario, all surnamed Saburao (Heirs of Saburao), affirming lower court rulings that their action for reconveyance over a parcel of land in Misamis Oriental had already prescribed and that they were guilty of laches.
In its decision in G.R. No. 269172, the Court denied the Petition for Review on Certiorari and affirmed the Court of Appeals Decision dated February 14, 2023, and Resolution dated August 25, 2023, in CA-G.R. SP No. 10129-MIN.
The Case
The case arose from a Complaint for Reconveyance and Partition filed by the Heirs of Saburao against the heirs of Patrocenia Saburao Villarte (Heirs of Patrocenia) involving Lot Nos. 7170 and 7140, located at Taytay, El Salvador, Misamis Oriental.
The Heirs of Saburao alleged that on November 16, 1943, a decree of registration, Decree No. M-66123, covering Lot Nos. 7170 and 7140 was issued in the name of Andres Saburao. Andres was the father of Santos, Simeon, Candido, Rosario, and Patrocenia, all surnamed Saburao, making him the predecessor of all the parties.
Despite the issuance of the decree, no certificates of title were issued over the lots. After Andres' death in 1947, his children decided to process the registration and chose Patrocenia, assisted by her daughter-in-law, to handle it.
On January 30, 1956, Original Certificate of Title (OCT) No. P-685 was issued covering Lot No. 7170, but it was registered in the name of Patrocenia only. The Heirs of Saburao said they did not act to correct this because they trusted their sister, and because Candido was then the occupant of the lot, with his son Joel continuing to occupy it.
The Heirs of Saburao argued that the free patent covering Lot No. 7170 could not have been obtained in 1956 since Decree No. M-66123 was already issued in 1943, meaning the Bureau of Lands no longer had jurisdiction to issue the free patent because the lot was already private property. They prayed that a title be issued in the name of the heirs of Andres and that the lots be partitioned.
The Heirs of Patrocenia claimed Patrocenia was the sole owner, having purchased the property from her siblings, and presented documents executed in 1955. They said Patrocenia secured Free Patent No. 25774 over Lot No. 7170, leading to the issuance of OCT No. P-685, and that she and her heirs paid real property taxes. Two years after the Complaint was filed, the DENR cancelled Patrocenia's free patent on the ground that a decree of registration covering the lot was issued in 1943.
The Issue
The Court addressed whether the Heirs of Saburao's action for reconveyance had prescribed and whether they were guilty of laches after their decades-long inaction.
The Ruling
The Court found that the Heirs of Saburao's action for reconveyance had already prescribed because decades had passed since the issuance of Patrocenia's OCT No. P-685, and the possession alleged by the Heirs of Saburao was not one that would render their action imprescriptible.
The Court also held that all the elements of laches were present. It ruled that the MTCC, the RTC, and the CA did not err in finding that the Heirs of Saburao slept on their rights and are guilty of laches.
The dispositive portion reads: "ACCORDINGLY, the Petition for Review on Certiorari is DENIED. The Decision, dated February 14, 2023, and the Resolution, dated August 25, 2023, of the Court of Appeals in CA-G.R. SP No. 10129-MIN are AFFIRMED."
By the Numbers
- November 16, 1943 — issuance of Decree No. M-66123
- 1947 — death of Andres Saburao
- January 30, 1956 — issuance of OCT No. P-685 and Free Patent No. 25774
- 1960 to 1980 — period Patrocenia and her heirs occupied the lot
- 60 years — the period of inaction by the Heirs of Saburao
- G.R. No. 269172
- CA-G.R. SP No. 10129-MIN
The Court's Reasoning
The Court explained that laches, also known as a stale demand, is grounded on public policy which necessitates, for the peace of society, the discouragement of stale claims. It is principally a question of the inequity or unfairness of permitting a stale right or claim to be enforced or asserted.
Applying the four essential elements of laches, the Court found that the Heirs of Saburao and their predecessors were aware at the outset that Lot No. 7170 was allegedly incorrectly registered under Patrocenia's name yet did nothing for six decades on the excuse that they were too "trusting." The Court stated that an ordinary, reasonable person would not just sit idly by for 60 years while property he believes belongs to him is registered in the name of another.
Citing Lorenzo v. Eustaquio and other cases, the Court noted that the Heirs of Saburao's inaction for 60 years constituted more than a considerable length of time. It held that the Heirs of Patrocenia, relying on the conduct of the Heirs of Saburao and on Patrocenia's valid title, were not aware the claim would be challenged, and that granting the relief would unduly prejudice them.
Source: Supreme Court Decision, G.R. No. 269172.
This report summarizes a public Supreme Court decision and is not legal advice.