Case Digest (G.R. No. 136506)
Facts:
In Department of Education, Culture and Sports (now Department of Education) represented by Regional Director Teresita Domalanta, filed on October 24, 2001, a Petition for Recovery of Possession in the Regional Trial Court of Tuguegarao City, Cagayan against the heirs of Regino Banguilan—Benigna Gumabay, Filomena Banguilan, Ester Kummer, Aida Banguilan, and Elisa Mallillin—who claimed ownership of a parcel in Caritan Norte, Tuguegarao City covered by Original Certificate of Title No. 10728. The respondents alleged that before World War II their predecessor, Regino, permitted the then Caritan Norte Elementary School (CNES) to erect temporary classroom structures on his land, later improved into permanent buildings. After Regino’s death in 1961, his heirs repeatedly demanded rent or sale of the lot, but no payment was ever made. They maintained that DepEd’s continued use deprived them of enjoyment and sought (1) declaration that school possession was unlawful, (2) vacation of the ...Case Digest (G.R. No. 136506)
Facts:
- Parties
- Petitioner: Department of Education, Culture and Sports (now Department of Education), represented by Regional Director Teresita Domalanta
- Respondents: Heirs of Regino Banguilan—Benigna Gumabay, Filomena Banguilan, Ester Kummer, Aida Banguilan, Elisa Mallillin
- Antecedent Events
- October 24, 2001: Respondents filed a complaint for recovery of possession with the RTC of Tuguegarao City, claiming ownership of Lot No. 3950 in Caritan Norte, Tuguegarao City under OCT No. 10728.
- Pre-World War II: Caritan Norte Elementary School (CNES) sought Regino’s permission to erect temporary classrooms on his land; permission granted. Structures were later improved to permanent buildings.
- Post-1961 (after Regino’s death): Respondents’ predecessors demanded rent or sale from school officials; no payments were made. Respondents alleged deprivation of use since 1950 and prayed that the school’s possession be declared unlawful, that DepEd vacate, and that DepEd pay P500/month rent from 1950, P30,000 litigation expenses, and P50,000 attorney’s fees.
- Proceedings Below
- RTC Decision (Sept. 11, 2012): Acknowledged respondents’ ownership under OCT No. 10728 but dismissed complaint on grounds of laches and prescription; suggested action for just compensation.
- CA Decision (Feb. 24, 2017): Reversed RTC; declared respondents lawful possessors; directed respondents to exercise their Article 448 options (appropriate improvements or compel purchase), ordered DepEd to pay P500/month rent from filing, attorney’s fees of P20,000 and costs.
- Petition for Review (Apr. 26, 2017): DepEd argued that respondents’ cause of action was barred by laches due to over fifty years’ inaction.
Issues:
- Whether the Court of Appeals erred in ruling that respondents’ cause of action for recovery of possession was not barred by laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)