G.R. No. 251233 - Alberto vs. Heirs of Panti

The Heirs of Juan A. Panti (Heirs of Panti) are the registered owners of a 16,210-square-meter parcel of land covered by Original Certificate of Title (OCT) No. 157 located at Calatagan, Virac, Catanduanes (subject property).
On May 19, 2008, Rosita U. Alberto (Alberto) caused the annotation of an Affidavit of Adverse Claim on OCT No. 157 before the Register of Deeds (RD) of Catanduanes. The Heirs of Panti alleged this adverse claim lacked clear and legal basis.
The Heirs of Panti filed a Petition for Cancellation of Affidavit of Adverse Claim before the Regional Trial Court (RTC) against Alberto and the RD of Catanduanes, praying that the adverse claim on the title be cancelled.

Asserted ownership under OCT No. 157.
Claimed Alberto's adverse claim was baseless, as no valid deed of sale was executed; only two receipts of partial payment dated 1966 were presented, falling within a prohibited five-year period for transfer of title from a free patent issued in 1965.
Argued the supposed sale was contrary to law and had no legal effect.

Contended she was an heir of the late Congressman Jose M. Alberto and that Spouses Alberto purchased the subject property from the Heirs of Panti in 1966 for valuable consideration.
Claimed that although the title remained under the Heirs’ name, they held it in trust for the Spouses Alberto.
Argued that her family had openly and peacefully possessed the property for over 40 years, paying real property taxes, and thus the annotation of the adverse claim was warranted to protect their rights and interests.

RTC (Branch 43, Virac, Catanduanes) initially denied the petition to cancel the adverse claim in a Decision dated December 9, 2008, finding Alberto’s adverse claim lawful and proper.
On appeal, the Court of Appeals (CA) in CA-G.R. CV No. 92294 reversed and remanded, noting the RTC failed to conduct a trial and merely ruled based on pleadings. The CA directed the RTC to hear evidence and determine the validity of the adverse claim.
After trial, the RTC reaffirmed its earlier decision in a January 8, 2018 Decision, again denying the petition to cancel the adverse claim. The Heirs of Panti filed a motion for reconsideration, which the RTC denied on February 9, 2018.
The Heirs of Panti appealed to the CA.
CA reversed the RTC Decision and granted the petition to cancel the adverse claim in a Decision dated May 27, 2019, with a subsequent Resolution dated January 15, 2020 denying Alberto’s motion for reconsideration.
Alberto filed the present Petition for Review under Rule 45 before the Supreme Court seeking reversal of the CA decisions.

Whether there is a valid and lawful basis for the annotation of the Affidavit of Adverse Claim on OCT No. 157 in favor of Rosita U. Alberto.

Whether the concept of laches applies to support the validity of Alberto’s adverse claim despite the apparent infirmities.