Title
Heirs of Bagaygay vs. Heirs of Paciente
Case
G.R. No. 212126
Decision Date
Aug 4, 2021
Anastacio's heirs contested a 1956 land sale to Eliseo, claiming it violated the 5-year prohibitory period. Court ruled the sale void ab initio, ordering land return and purchase price reimbursement, rejecting laches defense.
A

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)

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