Case Digest (G.R. No. 84051)
Facts:
The case involves the petitioners, Severo, Valentina, Rustico, Dominador, and Nicomedes Bergado, who are siblings claiming ownership of a parcel of land measuring approximately 5,900 square meters located in Pangasinan. This land was originally covered by Original Certificate of Title No. 16545, registered in the names of Alejandro Trinidad and Aniceta Soriano. Upon the death of the original owners, the property was inherited by their sole heir, Marciana Trinidad. On May 3, 1928, Marciana executed an Escritura de Compraventa, transferring the property to her parents, Pedro Bergado and Justina Galinato, who are the petitioners' parents. Subsequently, on February 19, 1947, Marciana sold the same property to the Parent-Teacher Association (PTA) of the Urdaneta Community High School. The petitioners assert their claim to the property through inheritance from their parents. However, the Republic of the Philippines claims ownership based on a donation made by the PTA on July 26...
Case Digest (G.R. No. 84051)
Facts:
Property in Dispute: The case involves approximately 5,900 square meters of land in Pangasinan, covered by Original Certificate of Title No. 16545 in the names of Alejandro Trinidad and Aniceta Soriano. The land was inherited by their sole heir, Marciana Trinidad.
First Sale (1928): Marciana Trinidad sold the property to Pedro Bergado and Justina Galinato (petitioners' parents) through an Escritura de Compraventa dated May 3, 1928.
Second Sale (1947): Marciana Trinidad sold the same property again on February 19, 1947, to the Parent-Teacher Association (PTA) of the Urdaneta Community High School.
Donation to the Republic (1977): The PTA donated the land to the Republic of the Philippines on July 26, 1977.
Petitioners' Claim: The petitioners, heirs of Pedro Bergado and Justina Galinato, claimed ownership of the property by inheritance. They argued that the Republic was barred from raising defenses of prescription and laches since these were not pleaded earlier.
Possession and Improvements: The PTA and later the Republic took possession of the land, constructed improvements (e.g., buildings, fences), and paid realty taxes. The petitioners did not protest these actions until 1981, when they filed a complaint to nullify the Republic's title.
Registration of Escritura de Compraventa: The petitioners registered the Escritura de Compraventa in 1964, 36 years after its execution, but did not take possession of the land.
Issue:
Prescription and Laches: Whether the petitioners' claim is barred by prescription and laches due to their inaction for over 30 years.
Double Sale: Whether the Republic, as the second buyer, has a superior claim over the petitioners under the rules of double sale.
Good Faith in Registration: Whether the petitioners' registration of the Escritura de Compraventa in 1964 was done in good faith, given their knowledge of the Republic's possession.
Applicability of Torrens System: Whether the petitioners' registered title under the Torrens system makes their claim imprescriptible.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)