Facts:

The case involves Aurora Alcantara-Daus as the petitioner and the spouses Hermoso and Socorro de Leon as the respondents. The dispute centers around a parcel of land located in the Municipality of San Manuel, Pangasinan, which was originally covered by Original Certificate of Title No. 22134. The respondents claimed ownership of the land, asserting that Hermoso de Leon inherited it from his father, Marcelino de Leon, through a Deed of Extrajudicial Partition. In the early 1960s, the respondents engaged the services of Atty. Florencio Juan to manage their property documents. After Atty. Juan's death, they discovered that several documents, including a Deed of Extrajudicial Partition and Quitclaim, had been signed without their intention to convey ownership. They alleged that Hermoso de Leon's signature on the quitclaim was forged and that the land had been sold to the petitioner by Rodolfo de Leon, who was not the rightful owner at the time of the sale. The respondents...

Facts:

Introduction and Procedural History

• The case is a Petition for Review under Rule 45 of the Rules of Court, challenging the Court of Appeals’ Decision (February 9, 2001) and Resolution (August 31, 2001) in CA-GR CV No. 47587.
• Petitioner: Aurora Alcantara-Daus.
• Respondents: Spouses Hermoso and Socorro de Leon.

Underlying Transaction and Land Description

• The dispute revolves around a parcel of land described as Lot No. 4786 (Cadastral Survey of San Manuel, Pangasinan) covering approximately 4,212 square meters and originally covered by Original Certificate of Title No. 22134.
• Respondents claimed ownership through inheritance and alleged that the title was acquired by virtue of a Deed of Extrajudicial Partition and Quitclaim executed on July 1, 1985.
• The land was allegedly sold by a member of the de Leon family (x x x Rodolfo de Leon) to petitioner on December 6, 1975.

Documentations and Transactions in Question

• The Deed of Absolute Sale supposedly executed on December 6, 1975, was the basis of petitioner’s claim of purchase in good faith.
• The Deed of Extrajudicial Partition and Quitclaim, purportedly executed in favor of x x x Rodolfo de Leon, is alleged by respondents to have been fraudulently executed, with a forged signature attributed to Hermoso de Leon.
• Respondents argued that various other documents revealed unauthorized conveyances which they claim were never intended.

Possession and Claims of Good Faith

• Petitioner asserts that she acquired the land in good faith by purchase, has been in continuous, public, and peaceful possession, and has appropriated the produce thereof without any objection.
• The dispute also involves the question of whether petitioner’s possession and claim over the land are adverse and possessory to such extent as to acquire ownership via prescription.

Decisions of Lower Courts

• The Regional Trial Court (RTC) ruled in favor of petitioner, holding that respondents’ claim was barred by laches due to the long lapse of time (more than 18 years) since the sale.
• The RTC further concluded that the notarial document (Deed of Extrajudicial Partition with Quitclaim) was presumptively authentic.
• Contrarily, the Court of Appeals reversed the RTC’s decision:
• It held that laches, being an equitable doctrine, could not bar the enforcement of a legal right.
• The Court of Appeals determined that since Rodolfo de Leon was not the owner at the time of the sale, he lacked the right to transfer ownership.
• The appellate court also found that the signature of Hermoso de Leon on the Deed of Extrajudicial Partition was forged, thereby undermining petitioner’s claim of being a bona fide buyer.

Issue:

Validity and Perfection of the Deed of Absolute Sale

• Whether the contract of sale, perfected by mere consent on December 6, 1975, is binding on the parties despite the seller’s lack of ownership at the time of sale.

Authenticity of the Extrajudicial Partition and Quitclaim

• Whether the notarial document (Deed of Extrajudicial Partition with Quitclaim) is authentic or if it is tainted by forgery, particularly in relation to the signature of Hermoso de Leon.
• Whether the evidence presented by respondents is sufficient to overcome the presumption of regularity normally afforded to such public documents.

Possession in Good Faith and Acquisition by Prescription

• Whether petitioner’s continuous, public, and peaceful possession of the land, inherited from her predecessor-in-interest Rodolfo de Leon, qualifies as possession in good faith for the purposes of acquiring ownership by prescription.

Prescription of Action and the Doctrine of Laches

• Whether the claim initiated by respondents on February 24, 1993, falls within the statutory prescriptive period (30 years) provided under Article 1155 of the NCC.
• Whether respondents are estopped by the doctrine of laches, despite the equitable nature of said doctrine and the competing legal rights involved.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)