Facts:

The case involves the Heirs of Gaudencio Blancaflor, who are the petitioners, against the Court of Appeals and Greater Manila Equipment Marketing Corporation, the respondents. The events transpired across several dates, primarily focusing on the proceedings dating back to May 16, 1968. On this date, the Court of First Instance of Rizal, in Civil Case No. 10270, ruled in favor of Sarmiento Trading Corporation against Gaudencio Blancaflor, ordering Blancaflor to pay a total of P9,994.05, plus interest, attorney's fees, and court costs. Following this judgment, a writ of execution was issued on August 26, 1968, leading to an auction sale where Blancaflor's property, identified as Lot No. 22, was sold to Sarmiento Trading Corporation. This sale was inscribed as a memorandum on the Transfer Certificate of Title (TCT) No. 14749 on December 19, 1968. On January 13, 1970, after the redemption period expired, a final deed was issued in favor of Sarmiento Trading Corporation.

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Facts:

Background of the Underlying Judgment

• On May 16, 1968, in Civil Case No. 10270, the then Court of First Instance (CFI) of Rizal, Branch 8, Pasig, rendered a judgment ordering Gaudencio Blancaflor to pay Sarmiento Trading Corporation the amount of P9,994.05, plus interest at 12% per annum from June 21, 1967, attorney’s fees of P500, and costs.
• A writ of execution was subsequently issued on August 26, 1968, to enforce this judgment.

Execution Sale and Issuance of the Certificate of Sale

• At the auction sale conducted by the sheriff on defendant Blancaflor’s property (Lot No. 22, covered by TCT No. 14749), Sarmiento Trading Corporation emerged as the highest bidder.
• The lot was sold to Sarmiento Trading Corporation, and the sheriff executed a certificate of sale, which was inscribed as a memorandum of encumbrance on TCT No. 14749 on December 19, 1968.

Subsequent Deed and Cancelling Proceedings

• On January 13, 1970, after the relevant one-year period, the final deed of sale was issued in favor of Sarmiento Trading Corporation.
• On March 20, 1970, upon petition before the CFI of Iloilo in Cadastral Case No. 4, Record No. 9739, the court ordered the cancellation of TCT No. 14749 in the name of Gaudencio Blancaflor and the issuance of a new certificate of title in the name of Sarmiento Trading Corporation. This order was annotated on TCT No. 14749 as Entry No. 139381.

Transfer to Successor-in-Interest and Subsequent Developments

• On June 2, 1972, Sarmiento Trading Corporation sold and transferred its interest in Lot No. 22 to Sarmiento Distributors Corporation.
• On September 26, 1988, officials from the Deeds Registry of Iloilo City requested Gaudencio Blancaflor to surrender his owner’s duplicate copy of TCT No. T-14749.
• Failing any new issuance by the Registrar of Deeds, on February 10, 1989, and with an amended petition on May 25, 1989, private respondent Greater Manila Equipment Marketing Corporation (formerly Sarmiento Distributors Corporation) initiated litigation before the Regional Trial Court (RTC). They prayed that the heirs of Gaudencio Blancaflor surrender the owner’s duplicate copy of TCT No. T-14749, or in the alternative, that it be cancelled, in addition to the cancellation of the levy notice pertaining to Civil Case No. 11562.

RTC Decision and Appeal

• The RTC granted the petition, ordering the heirs of Gaudencio Blancaflor to surrender the owner’s duplicate copy of TCT No. T-14749 within fifteen (15) days, or else face its nullification, with an instruction to the Register of Deeds to issue a new certificate of title in favor of the petitioner.
• Petitioners, the heirs of Gaudencio Blancaflor, appealed the RTC decision through the Court of Appeals, arguing that the causes of action had prescribed, citing the elapsed time and challenges related to prescription and laches.

Procedural and Legal Maneuvers

• Petitioners contended that the causes of action deriving from:
• The original 1968 judgment, its execution (writ of execution and final deed of sale), and the 1970 cadastral decision had prescribed under Article 1144 of the New Civil Code.
• The belated filing of the petition in 1989 was strategically timed after the demise of Gaudencio Blancaflor.
• Private respondent Greater Manila Equipment Marketing Corporation countered by asserting that the petition was not an execution of the judgment but rather a completed step to perfect the involuntary conveyance by compelling the surrender of the owner’s duplicate certificate pursuant to the administrative and judicial procedures provided by law.

Issue:

Prescription and Laches

• Whether the causes of action for enforcing the surrender and/or cancellation of the owner’s duplicate copy of TCT No. T-14749 had already prescribed under Article 1144 of the New Civil Code.
• Whether the doctrine of laches was applicable due to the delay in filing the petition and the alleged preclusion of rights following the demise of Gaudencio Blancaflor.

Nature and Timeliness of the Cause of Action

• Determining if the petition for surrender of the owner’s duplicate certificate was based on enforcing a judgment that had already been executed, or if it constituted a separate cause of action merely aimed at perfecting the transfer of title.
• Evaluating whether the petitioner’s actions, following the statutory and administrative guidelines under Section 107 of P.D. 1529 and Section 78 of Act No. 496, were proper and timely.

Role of Administrative and Judicial Procedures

• Whether the proper legal processes—registration of the certificate of sale, inscription of the notice of levy, and the subsequent administrative obligations imposed on the registered owner—were duly observed.
• If the constructive notice provided by the registration of the encumbrances and deeds sufficed to bar the petitioners’ claims regarding lack of notice or improper procedure.

Ruling:

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Ratio:

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Doctrine:

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