G.R. No. 262600 - People vs. AAA

The subject property is a fourteen (14)-hectare parcel located in Pugo, La Union, which was originally surveyed by Fernando Nantes in connection with his application for a free patent.
Free Patent No. 6381 was issued on November 1, 1918, and Original Certificate of Title (OCT) No. 470 on November 11, 1918, covering the entire parcel.
In 1930, Fernando Nantes sold the lot to Rosendo Farales, who then sold it in 1931 to Apolinario Fama, father of the petitioners.
OCT No. 470 was replaced by Transfer Certificate of Title (TCT) No. 257 in the name of Apolinario Fama.
In 1947, Maria Fama Florentin, one of the heirs, petitioned for the reconstitution of the lost TCT, and in 1948 TCT No. RT-223 (257) was issued covering the entire property.

Respondents claim that they and their predecessors-in-interest have occupied the subject land since time immemorial, asserting continuous, open, notorious, public, and exclusive possession.
They allege that even before the issuance of a patent in 1918, their ancestors possessed portions of the land, particularly the Ambangonan barrio site.
Petitioners, on the other hand, claim that they validly acquired the property through purchase from Apolinario Fama’s title, which was later confirmed by the government via the Torrens system.

In 1950, Maria Fama Florentin filed a case against Lazaro Galera to recover an 11,000-square meter portion of the land; the Court of First Instance dismissed Galera’s claim after finding no fraudulent title acquisition by Fernando Nantes.
Petitioners subsequently sent demand letters in 1972 to the occupants (respondents), but later in 1974 filed a complaint for recovery of possession with damages (Civil Case No. A-424).
Conversely, respondents initiated a complaint for quieting of title, partition, and damages in 1984 (Civil Case No. A-953), alleging adverse possession and asserting that petitioners acquired the title in bad faith.
The RTC of Agoo, La Union, Branch 31 rendered a decision on October 6, 1997 in favor of petitioners, ordering respondents to vacate the property (with exceptions for government and community structures).
On appeal, the Court of Appeals (CA) reversed parts of the RTC decision by dismissing the recovery of possession complaint against some respondents while remanding the case for further evidence regarding possession of others.

Testimony by Maria Fama Florentin indicated that respondents first entered the property without consent in 1937 and later made improvements such as constructing houses, planting trees, and establishing rice plantations and mills.
Respondents presented unified testimonies affirming that their ancestors had maintained continuous and adverse possession for over a century.
Documentary evidence included vintage tax declarations, receipts for realty taxes, and road tax certificates in the names of respondents and their predecessors.
However, some alleged documents—such as the deed of quitclaim or annotated title cited by respondents—were not produced, weakening their evidentiary position.

In 1984, the Sangguniang Bayan of Pugo, La Union, expressed support for respondents by filing a resolution and petition for the nullification of petitioners’ title over parts of the land and for a resurvey of certain areas.
The land has been registered and reconstituted through three distinct processes under the Torrens system, thereby affording petitioners a title that is legally indefeasible under the law.

Whether the right of the respondents to continue in possession of the subject land, based on long and adverse possession, prevails over the substantive Torrens title held by the heirs of Apolinario Fama.

Does the evidence of long-standing possession by respondents (and their predecessors-in-interest) qualify under acquisitive prescription or adverse possession despite the early issuance of a free patent and subsequent Torrens registration?

Whether petitioners’ delay in instituting legal action against respondents constitutes laches, thereby affecting their claim to recover possession.

The determination includes examining if the petitioners’ inaction for over four decades barred their recovery of possession by allowing the respondents’ adverse possession to ripen.

Whether the proper procedures and safeguards mandated by the Torrens system and relevant statutes (such as Act No. 496 and Republic Act No. 26) provided sufficient notice to respondents, thereby binding them to the registered title.