Case Digest (G.R. No. L-27088)
Facts:
Heirs of Batiog Lacamen v. Heirs of Laruan, G.R. No. L-27088, July 31, 1975, Supreme Court First Division, Martin, J., writing for the Court.Petitioners are the surviving heirs of Batiog Lacamen; respondents are the heirs of Laruan. On January 28, 1928, Laruan executed a Deed of Sale in favor of Batiog Lacamen for P300 conveying an 86 ares and 16 centares parcel in sitio La Trinidad, Benguet, covered by Certificate of Title No. 420; the deed was acknowledged before a notary public. Immediately after the sale Laruan delivered the certificate of title to Lacamen, who entered into open, continuous, peaceful and adverse possession in concepto de dueño, made improvements and paid taxes; Lacamen died in April 1942 and his heirs continued possession and tax payments.
After World War II, in or about June 1957, Lacamen’s heirs discovered that respondents had procured an owner’s copy of Certificate of Title No. 420 by a court petition alleging the original was lost and thereby caused transfer of the title into their names as Transfer Certificate of Title No. T-775. Petitioners’ demands for reconveyance were refused and, on December 9, 1957, they sued respondents in the Court of First Instance of Baguio City praying for declaration of ownership, reconveyance, cancellation of TCT No. T-775 and issuance of a new title in their names. Respondents denied the sale, alleged Laruan never sold and argued the deed lacked a thumb mark.
On April 5, 1962 the Court of First Instance of Baguio City ruled for respondents. On December 7, 1966 the Court of Appeals affirmed the trial court. Petitioners filed a petition for review by certiorari to the Supreme Court. The lower courts based their rulings on statutory provisions requiring approval of land transactions by non-Christian natives (inter alia, Ad...(Pro-only)
Issues:
- Under the statutory scheme governing land transactions by non-Christian/illiterate natives (Administrative Code Secs. 145–146; Act No. 2874 Secs. 118, 122; Act No. 2798), is the sale from Laruan to Lacamen void for lack of approval by the proper executive authority?
- If the sale was technically void, does the doctrine of laches bar respondents-appellants from asserting title so that petitioners-appellants who possessed, improved and paid taxes on the land for ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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