G.R. No. 159085 - Sanlakas vs. Reyes

A 5,354-square meter parcel of land located in the former Municipality of Opon, Province of Cebu (now Marigondon, Lapu-Lapu City) is at issue.
The property was originally titled in the name of Mamerto Ingjug and later inherited by his five children: Romana, Francisco, Francisca, Luisa, and Maria, all surnamed Ingjug.
Petitioners are the heirs of Romana, Francisco, and Francisca Ingjug, asserting rightful succession and co-ownership in the property.
Respondents are a group of vendees, comprising spouses Leon V. Casals and Lilia C. Casals; spouses Carlos L. Climaco and Lydia R. Climaco; spouses Jose L. Climaco, Jr. and Blanquita C. Climaco; and Consuelo L. Climaco, who acquired the property through a sale transaction.

On July 9, 1965, Luisa, Maria, one Eufemio Ingjug, and Guillerma Ingjug Fuentes-Pagubo (daughter of Francisca) purportedly sold the disputed parcel to the respondents.
The sale was corroborated by a Deed of Sale of Unregistered Land and a subsequent Extrajudicial Settlement and Confirmation of Sale executed by the vendors.
It was allegedly represented that the vendors were the sole surviving heirs of the late Mamerto Ingjug, thus implying their exclusive authority to convey the property.

Upon the death of Mamerto Ingjug during the Second World War, the title devolved upon his heirs, creating a scenario of undivided co-ownership.
The property had not been partitioned among the heirs, and its sale by some heirs without the knowledge or consent of the others raised issues regarding the legitimacy of the disposition.

On August 10, 1992, petitioners (the heirs of Romana, Francisco, and Francisca) filed a complaint for partition, recovery of ownership and possession, and declaration of nullity of the contested sale and extrajudicial settlement.
Petitioners alleged that the sale was executed without their consent, involved fraud, misrepresentation, and unauthorized disposition of their hereditary rights.
They contended that the disputed contracts are null and void ab initio on the ground that not all compulsory heirs consented to the sale, and that some signatories (e.g., Francisco Ingjug and Eufemio Ingjug) lacked the requisite capacity or standing.

The trial court dismissed the complaint on the grounds of prescription and laches.
The Court of Appeals later affirmed the dismissal, holding that the defendants had acquired the property through adverse possession by prescription, and that petitioners’ rights had effectively lapsed.
Respondents who did answer contended that, not only was the sale executed in good faith, but they acquired the property pending the reconstitution of the lost original certificate, which was subsequently replaced by a new Transfer Certificate of Title.

Petitioners questioned the identity and capacity of some of the vendor-signatories, asserting that Eufemio Ingjug was a son-in-law rather than a direct heir, and that Francisco Ingjug could not have been a valid party to a deed executed in 1967 since he had died in 1963.
They also alleged that respondents had failed to pay the necessary taxes and had not taken actual possession or improved the property, thereby casting doubt on their status as bona fide purchasers for value.
Petitioners further argued that the land, being originally registered under the Torrens system, is not subject to prescription or adverse possession, and that rights to recover possession remain imprescriptible.

Whether petitioners’ right to institute actions for partition, recovery of ownership and possession, and for the nullity of the disputed sale is barred by prescription and laches.

Whether the disputed Deed of Sale and the Extrajudicial Settlement and Confirmation of Sale are null and void ab initio due to the absence of consent from all compulsory heirs and the participation of parties lacking contractual capacity.
Whether the doctrine of prescription applies to a property originally entitled under the Torrens system, and if so, whether such prescription bars a claim even when underlying contracts are alleged to be void.
Whether laches is a tenable defense in a context where petitioners claim an imprescriptible right to recover their hereditary interest.
Whether the respondents, having acquired the property allegedly in good faith, are in fact bona fide owners or merely holders in trust for the petitioners.
Whether the summary dismissal of the case by the trial court was proper in light of the disputed factual issues, particularly those involving fraud, misrepresentation, and unauthorized disposition by some heirs.