G.R. No. 123823 - Espano, Sr. vs. Court of Appeals

On May 27, 1994, private respondent Caridad Jinon filed Civil Case No. 21-88 before the Regional Trial Court (RTC) of Iloilo City, Branch 31, seeking annulment of title, recovery of possession, declaration of ownership, reconveyance, and damages.
The dispute involves two parcels of land identified as Lot Nos. 2843 and 1941, which are allegedly registered and titled in the name of petitioner Modesto G. EspaaO, Sr. under Transfer Certificate of Title Nos. T-55995 and T-74937, respectively, covering portions of the Cadastral Survey of Sta. Barbara, Leganes, Iloilo.

Private respondent Caridad Jinon asserts her ownership by way of succession from her grandparents, in representation of her deceased father, Mateo Jinon.
Her claim is substantiated by a Partition Agreement (Convenio de Particion) dated April 6, 1927, executed among herself, her uncles, and other co-heirs (Eusebio, Manuel, Anastacio, and Eladio Jinon).
Petitioner EspaaO, in his answer with counterclaim, raised affirmative defenses, notably laches and prescription, contesting respondent's claims.

Petitioner EspaaO contended that both properties were registered in his name: TCT No. 55995 (Lot 2843) on August 8, 1968, and TCT No. T-74937 (Lot 1941) on March 22, 1973.
He argued that 25 years (for Lot 2843) and 20 years (for Lot 1941) had elapsed by the time the suit was filed, thus invoking the ten-year prescriptive period for reconveyance based on implied trust.
Preliminary hearings on the affirmative defenses were scheduled on October 28 and December 16, 1994.
Instead of presenting evidence at the preliminary stage, petitioner moved for the dismissal of the case by merely alleging the grounds of laches and prescription in his pleadings.
The RTC ruled that laches and prescription are evidentiary defenses which cannot be conclusively established by mere allegations; they must be substantiated during the trial on the merits.
A subsequent Order dated February 28, 1995, deferred the resolution of these defenses to the trial on the merits, and a motion for reconsideration filed by petitioner was denied on April 21, 1995.

On June 2, 1995, petitioner EspaaO filed a petition for certiorari before the Court of Appeals to annul both the RTC’s February 28, 1995 Order and the April 21, 1995 denial of his motion for reconsideration, alleging grave abuse of discretion amounting to lack of jurisdiction.
The Court of Appeals dismissed the petition on August 17, 1995.
A subsequent motion for reconsideration before the trial court was also denied in a resolution dated February 8, 1996.
Petitioner then elevated the issue to the Supreme Court through this petition.

Whether or not the affirmative defenses of laches and prescription, raised by petitioner EspaaO, are valid grounds for dismissing the suit filed by respondent Jinon.

Does the alleged passage of 25 and 20 years from the registration dates of the respective titles suffice to invoke prescription as a bar to respondent’s claim?
Can the doctrine of laches, which requires proof of unreasonable delay and prejudice, be established solely on the allegations in the petition without supporting evidentiary backing?
Whether the trial court committed grave abuse of discretion in deferring the resolution of laches and prescription to the trial on the merits, thereby justifying the petitioner’s petition for certiorari.