G.R. No. 125509 - Public Interest Center, Inc. vs. Roxas

The petitioners are the Heirs of Enrique Diaz, represented by Aurora T. Diaz, while the respondent is Elinor A. Virata acting as the administratrix of the Estate of Antenor Virata.
The dispute involves a long-running controversy over titles and possession of several parcels of land in Palico, Imus, Cavite, which were originally acquired by the late Antenor Virata.
The litigation stemmed from conflicting claims arising from the demise of the patriarchs of two families, with subsequent actions pursued by their respective heirs.

The case originated in the Regional Trial Court (RTC), Branch 22, Imus, Cavite, in Civil Case No. 1399-96, where the respondent filed a Complaint on 13 September 1996 seeking a temporary restraining order and/or preliminary injunction.

The respondent’s Complaint asserted that Antenor, the original owner, had purchased the properties and subsequently subdivided them, resulting in several Transfer Certificates of Title (TCTs) being issued in his name.
The respondent contended that Enrique Diaz had, in March 1992, filed a claim with the Department of Environment and Natural Resources (DENR) to assert continuous possession over the properties, alleging that such claim cast a cloud over the titles.

Enrique Diaz, the defendant in the RTC proceedings, filed an Answer with a Counter-Claim on 23 October 1996.

His Answer denied the respondent’s allegations of purchase and possession, asserting instead that his family had been in continuous, peaceful possession of the property since time immemorial.
He also raised affirmative defenses including the doctrines of laches and res judicata based on a prior dismissed case (Civil Case No. N-501) for recovery of possession.

The RTC allowed the survey of the property, leading to a relocation survey conducted in January 1997 which confirmed encroachments by structures allegedly built by Enrique Diaz.
The respondent filed an Amended Complaint on 19 February 1997, modifying her initial allegations and seeking additional relief such as eviction orders and demolition of illegal constructions (fences, concrete house).
Enrique Diaz filed various motions including a Motion for Leave to File an Amended Answer, which was denied on 14 January 1998.
The case saw further procedural orders, including a pre-trial order dated 4 June 1998, subsequent default orders, and motions for reconsideration which were granted to lift a default order.
Trial proceedings commenced with evidentiary presentations and motions to dismiss were filed; however, the trial court ultimately rendered a Decision on 25 May 2001 in favor of the respondent.

In 1959, Antenor Virata purchased two parcels of land in Palico, Imus, Cavite from Miguela Crisologo.

The properties were originally covered by TCT Nos. T-3855 and T-11171, registered in the name of Miguela Crisologo.
Upon full payment, the original titles were cancelled and replaced with TCT Nos. T-517 and T-518 issued to Antenor.

In 1963, after subdividing the properties, additional TCTs were issued (TCT Nos. T-4983, 4984, 4985, 4986, 5027, 5028, 5029, 5030, 5031, 5032, and 5033), all bearing Antenor’s name.
After Antenor’s death in 1969, his niece, Elinor Virata, was appointed administratrix of his estate on 4 May 1982 by the Court of First Instance of Cavite City.

Enrique Diaz, apart from asserting continuous and actual possession of his ancestral lands, filed a protest with the DENR in 1992, claiming rights over portions of the properties.
Enrique also raised defenses based on the equitable doctrines of laches (asserting respondent’s undue delay) and res judicata (arguing that a previous case, Civil Case No. N-501—a recovery of possession suit—should bar the present action).
Throughout the proceedings, various motions, pleadings, and evidentiary submissions were filed by both sides, including motions challenging the substance of the titles and the conduct of the litigation, such as an attack on the certificate of title via alleged defects in its administrative reconstitution.

Whether the titles, originally issued in the name of Antenor Virata (TCT Nos. T-4983, 4984, 4985, 4986, 5027, 5028, 5029, 5030, 5031, 5032, and 5033), are valid and constitute the only official and recognized titles covering the disputed properties.
Whether any alleged administrative defects, such as the reconstitution of TCT No. (T-11171) RT-1228 and the absence of corresponding records, amount to a valid collateral attack on the titles.

Whether respondent is entitled to recover possession of the subject properties based on her title as administratrix.
Whether defenses raised by Enrique Diaz—specifically, the doctrines of laches and res judicata derived from the prior dismissed action (Civil Case No. N-501)—are applicable to bar the present claims.
Whether the delay in instituting the present action (purportedly 27 years since the earlier case) can constitute a bar to recovery by invoking the equitable doctrine of laches.

Whether the RTC had jurisdiction to entertain and decide on the issues of title and possession, and whether the challenge to that jurisdiction raised by Enrique Diaz had merit.
The propriety of consolidating actions for quieting of title and recovery of possession within the same proceedings.

Whether the award of attorney’s fees to the respondent, as initially granted by the RTC, is justified based on the evidence and findings in the case.