Case Digest (G.R. No. 212126)
Facts:
The case involves a dispute between the heirs of Eliseo Bagaygay (petitioners) and the heirs of Anastacio Paciente, Sr. (respondents) over ownership and possession of a parcel of land in Barangay Dajay, Surallah, South Cotabato, Philippines. On October 8, 1953, Anastacio was granted a homestead patent over approximately 7.9315 hectares, with Original Certificate of Title (OCT) No. V-2423 issued on October 24, 1953, in his name. Subsequently, a Deed of Sale was allegedly executed by Anastacio selling the land to his brother-in-law Eliseo Bagaygay, who took possession and transferred the title under his name, subdividing the land into three lots covered by Transfer Certificates of Title (TCT) Nos. T-34610, T-34611, and T-34612.
Anastacio died in 1989, Eliseo in 1991, after which Eliseo’s wife Anecita and their children (petitioners) possessed the land. In 1999, the heirs of Anastacio (respondents) filed a case before the Regional Trial Court (RTC) of Surallah, South Cotabato, see
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Case Digest (G.R. No. 212126)
Facts:
- Grant and Original Title
- On October 8, 1953, Anastacio Paciente, Sr. was granted a homestead patent for a 7.9315-hectare land parcel in Barrio II, BaAga, Province of Cotabato (now Barangay Dajay, Surallah, South Cotabato).
- On October 24, 1953, Original Certificate of Title (OCT) No. V-2423 was issued in Anastacio’s name.
- Alleged Sale and Transfer of Title
- Anastacio allegedly executed a Deed of Sale in favor of his brother-in-law, Eliseo Bagaygay, who took possession of the land.
- Eliseo later transferred the title under his name and subdivided the land into three lots covered by Transfer Certificates of Title (TCT) Nos. T-34610, T-34611, and T-34612.
- Deaths and Possession
- Anastacio died on March 7, 1989; Eliseo died two years later on March 18, 1991.
- Eliseo’s heirs—petitioners Anecita P. Bagaygay and children—took possession of the land upon his death.
- Complaint by Respondents
- On December 21, 1999, heirs of Anastacio (respondents) filed an action before the RTC of Surallah for:
- Declaration of nullity of the Deed of Sale and titles;
- Recovery of ownership and possession;
- Accounting and damages.
- Respondents alleged that Eliseo took advantage of Anastacio’s financial distress in 1956 to obtain the land title fraudulently.
- They claimed Anastacio never sold the land and that the Deed of Sale was executed within the five-year prohibition period under Section 118 of the Public Land Act.
- Procedural History and Evidence at Trial
- Petitioners moved to dismiss citing failure to state cause of action, prescription, and laches but failed.
- Petitioners filed an answer with a compulsory counterclaim, asserting the validity of the purchase and raising prescription and laches as defenses.
- Respondents presented:
- Testimony of Registrar of Deeds witness identifying Primary Entry Book indicating Deed of Sale executed November 28, 1956;
- Eliseo’s title with annotation regarding loss of original OCT and reference to the 1956 Deed of Sale;
- Testimonies of respondent witnesses Meregildo and Arturo, attesting to possession since 1956 and the nature of the land transaction as a loan guarantee.
- Petitioners presented testimonies of family members and a neighbor to affirm that:
- The Deed of Sale was executed in 1958, not 1956;
- The sale was to defray respondent Meregildo’s wedding expenses in June 1958;
- The Deed of Sale was notarized by Judge Aurelio Rendon;
- Documents destroyed by fire in 1994 prevented presentation of the original Deed of Sale;
- Marriage Contract of Meregildo and Judge Rendon’s bar admission date corroborated the 1958 date.
- RTC Decision
- On July 2, 2007, the RTC dismissed the complaint and counterclaims for lack of merit.
- RTC credited the petitioners’ witnesses over respondents’, finding the sale was valid and made in 1958 beyond the five-year prohibition period.
- Court of Appeals Decision
- The CA reversed the RTC, giving more weight to the documentary evidence (Primary Entry Book) over petitioners' testimonial evidence.
- The CA declared the Deed of Sale void ab initio for being executed within the five-year prohibition period (November 28, 1956).
- CA ordered cancellation of Eliseo’s titles and reinstatement of title in respondents’ names with reimbursement of purchase price to petitioners.
- CA denied petitioners’ motion for reconsideration in a February 26, 2014 Resolution.
- Petitioners’ Appeal to the Supreme Court
- Petitioners raised errors:
- CA erred in discounting factual findings of RTC, overruling the 1958 date for execution of the Deed of Sale;
- CA failed to apply the doctrine of laches against respondents given their delayed filing of suit.
- Petitioners stressed the marriage date of Meregildo as proof of the timing of the sale.
Issues:
- Whether the Court of Appeals erred in ruling that the Deed of Sale was executed on November 28, 1956, within the five-year statutory prohibition, thus rendering it void ab initio.
- Whether the doctrine of laches applies against respondents due to delayed filing of the action.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)