G.R. No. 177600 - Balindong vs. Court of Appeals

Petitioners: Heirs of Evarista delos Reyes, including Arsenio, Felicidad, Benjamin, Salvador, Soledad (with spouse Pedro Parinao), Trinidad (with spouse Pedro General), Carlos Jr., Roberto, Rodolfo, Ricardo, Zenaida, Veronica, Mercedes (all Delos Reyes), and Felipe, Gregoria, Lucena, Virgilio, and Mercedes (all Cantillon). They assert rights as successors in interest derived from the original ownership of a parcel of land.
Respondents: Rodolfo CaiAa and Zenaida CaiAa, who acquired full ownership and possession of the subject property through a valid transaction.

Original Property Description: A parcel measuring 13,405 square meters originally owned by Genaro and Evarista delos Reyes.
Key Transactions:

7 July 1942: Evarista delos Reyes sold 10,000 square meters (Lot No. 1210) from the property to spouses Catalina Mercado and Eulalio Pena.
4 June 1943: The vendees secured Transfer Certificate of Title (TCT No. 26184) covering not only the 10,000 square meters purchased but also an additional 3,405 square meters that were not part of the sale.
Subsequent Conveyances: The Pena spouses subsequently sold the whole property to Isaias de Guzman and Emiliana de Onon, who later conveyed it to a group of individuals, ultimately culminating in the property passing to the private respondents.
9 July 1963: Respondents acquired the property through a deed of exchange.
17 July 1963: TCT No. 42753 was issued in the name of the respondents, confirming their legal title.

3 October 1978: Petitioners filed an action seeking reconveyance of the disputed 3,405 square meters, contending that it was erroneously included in the title, as it was not part of the original transaction.
28 July 1987: The Regional Trial Court of Valenzuela, Metro Manila, dismissed the intervention for recovery of possession on the ground of laches (undue delay).
23 January 1995: The Court of Appeals affirmed the dismissal rendered by the Regional Trial Court.
Supreme Court Petition: Petitioners sought nullification of the appellate decision by challenging:

The computation of the 30-year prescriptive period (arguing it should commence either from the death of Evarista delos Reyes in 1962 or the issuance of TCT No. 42753 in 1963, rather than from 1943).
The non-application of Civil Code provisions (Arts. 1409, 1410, and 1422) allegedly protecting void and inexistent contracts.

The correct starting point for the 30-year prescriptive period under Art. 1141 of the Civil Code and Section 44(b) of RA No. 296.
The applicability of the doctrines on laches and on the imprescriptibility of void contracts versus the reconveyance action filed by the petitioners.
The protection afforded to the respondents as innocent purchasers for value under the Torrens system and the resulting effect on subsequent claims for reconveyance.

Whether an action for reconveyance of real property under the Torrens system filed after more than thirty (30) years may successfully proceed against an innocent purchaser holding a valid title.
Whether the 30-year prescriptive period for real actions should be computed from the date of the erroneous registration in 1943, or alternatively from the death of the original owner in 1962 or the issuance of TCT No. 42753 in 1963.
Whether the pertinent provisions of the Civil Code (Arts. 1409, 1410, and 1422) on the imprescriptibility of void and inexistent contracts may be rightly applied to a reconveyance action.
Whether the doctrine of laches should bar the petitioners’ claim given the significant delay (36 years) in asserting their right of reconveyance.