G.R. No. 165014 - Heirs of Delfin vs. Rabadon

The case involves petitioners—Heirs of Alejandra Delfin (including Luz C. Delfin, Lelane C. Delfin, Anastacia C. Delfin, Marcelito Delfin, Francisco Delfin, Apollo Delfin, Abriles Delfin, Lydia D. Daculan, Olivia D. Caballero, Alejandro Delfin, Julito Delfin, and Candido Delfin, Jr.)—versus respondents comprising Avelina Rabadon, Paciano Panogal-ing, Hilaria Rabadon, Pablo Boquilla, Catalina Rabadon, Paciano Rabaya, Fe Rabadon, Gonzalo Dabon, and Roberto Rabadon.
The dispute centers on the ownership and possession of Lot No. 8217, a 4,452-square-meter parcel of land in Inawayan, Pardo, Cebu City.
The controversy arose from competing claims based on differing evidentiary bases—documents and declarations from each side—to prove the right over the subject property.

On October 19, 1993, respondents filed an action before the Regional Trial Court (RTC) to recover ownership and possession of the subject property, also seeking damages.

Respondents alleged that the property had been originally owned by their predecessor-in-interest, Emiliana Bacalso, as evidenced by Decree No. 98992.
Although the original decree and certificate of title were lost during World War II, its existence was corroborated by an LRA certification and a certified daybook entry from the Register of Deeds.
They contended that the property passed into possession via the chain of inheritance—from Emiliana to Genaro Rabadon, and subsequently to the respondents.
In 1989, respondents discovered that petitioners and some of their family members had taken possession of the property, building houses on the lot.

They inherited the property from their predecessor-in-interest, Remegio, who allegedly bought the land even before World War II.
A certificate of title had been issued in Remegio’s name, though the said title was lost.
Ownership was further consolidated through an extra-judicial settlement by which Alejandra Delfin and her children assumed actual possession.
The property was consistently declared for taxation purposes, with corresponding realty taxes duly paid.
An affirmative defense of laches was raised, arguing that respondents delayed the filing of their complaint—reportedly taking about 55 years—to assert their rights.

The RTC ruled in favor of petitioners, basing its decision on the continuous declaration of the property for taxation purposes and proof of tax payments.
It noted that while tax declarations and receipts do not conclusively establish ownership, they gain probative value when coupled with proof of actual possession.
The court also highlighted that respondents had made no efforts to reconstitute or locate the original certificate of title issued to Emiliana.
The RTC additionally found respondents guilty of laches.

The CA reversed the RTC’s ruling, holding that respondents had demonstrated a better right to ownership and possession.
The CA critiqued petitioners’ reliance on tax declarations and receipts in the absence of other evidence of possession.
It gave greater weight to respondents’ evidence (e.g., the LRA certification, daybook entry, and witness testimony) that established the existence of Decree No. 98992.
The CA further dismissed the laches defense by noting that petitioners failed to prove possession since 1938 and that respondents had timely asserted their claim.
The CA ordered respondents to reimburse petitioners for taxes paid during the period of possession, with legal interest.

Petitioners filed a motion for reconsideration, which was denied by the CA Resolution dated August 2, 2004.
The present petition for review on certiorari was filed thereafter.

Whether respondents have the better right to the ownership and possession of Lot No. 8217, despite petitioners’ claims based on tax declarations, tax receipts, and alleged extra-judicial settlement.

Whether the evidence adduced by petitioners proving their claim (notably the tax declarations and receipts) is sufficient to rebut respondents’ evidence establishing the existence of Decree No. 98992.
Whether the alleged delay (laches) by respondents in filing their complaint prejudiced petitioners’ rights.