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...

Facts:

Parties and Title History

• The property in dispute is approximately 5,900 square meters located in Pangasinan, originally registered under Original Certificate of Title No. 16545 in the names of Alejandro Trinidad and Aniceta Soriano.
• Marciana Trinidad, the sole heir, inherited the property and subsequently executed an Escritura de Compraventa on May 3, 1928, transferring the land to Pedro Bergado and Justina Galinato (the petitioners’ parents).
• The property was conveyed once more by Marciana Trinidad through a Deed of Sale dated February 19, 1947, to the Parent-Teacher Association (PTA) of the Urdaneta Community High School.

Possession and Subsequent Developments

• After the 1947 sale, the PTA took immediate possession of the land, constructing various improvements including the right wing of the main building, an administration building, annexes, a reading center, and a water reservoir.
• The PTA also secured the property physically by first enclosing it with a barbed wire fence and later an adobe wall (erected before 1965–1966), marking an unmistakable act of ownership.
• On July 26, 1977, the property was donated by the PTA to the Republic of the Philippines, which continued to occupy and further develop the land.

Petitioners’ Claims and Conduct

• The petitioners, as heirs of Pedro Bergado and Justina Galinato, claim right to the property by inheritance based on the earlier Escritura de Compraventa executed in 1928.
• Despite being aware of the PTA’s controlled possession and subsequent governmental occupation, the petitioners maintained a prolonged silence for over three decades regarding their claim.
• Their first protest came only in 1981 when they filed a complaint seeking to nullify the private respondent’s title to the disputed land.

Procedural Posture and Contentions

• The lower courts (trial court and Court of Appeals) ruled in favor of the Republic of the Philippines, holding that the petitioners’ claim was barred by the doctrines of prescription and laches.
• The petitioners argued that the defenses of prescription and laches, not being raised at the proper stage (pre-trial or in the answer), should not preclude their claim.
• They further contended that since the property title is registered under the Torrens system, it should be considered imprescriptible, and in the context of a double sale, priority should go to the party who first registers in good faith.

Issue:

Whether the petitioners’ right to claim the disputed property is barred by the doctrine of prescription due to the undue lapse of time from the cause of action’s accrual.

• Consideration of the ten-year limitation period for an action of recovery of title or possession.
• Analysis of when the cause of action accrued (either in 1947 or no later than 1965–1966).

Whether the doctrine of laches applies, given the petitioners’ prolonged inaction and delayed assertion of their right.

• Determining if their thirty-four-year silence amounts to a waiver of their claim through laches.
• Evaluating whether such inaction contributed to the inequity of allowing their claim to proceed.

Whether the defenses of prescription and laches could validly bar the petitioners' claims even though these were not raised at the pre-trial stage.

• The propriety of raising such defenses based on the available evidence in the record.
• Discussion on the pre-trial procedure and its role in preventing surprise and undue maneuvering.

The applicability of the Torrens system’s principle regarding the finality and imprescriptibility of registered titles versus unregistered or inchoate claims.

• Whether the petitioners’ late registration in 1964 (36 years after the execution of the Escritura de Compraventa) can convert their right into ownership.
• Comparison with the Republic’s possession and the bright-line rule in cases of double sale, favoring first possession in good faith.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)