Title
Pangasi vs. Disonglo-Almazora
Case
G.R. No. 200558
Decision Date
Jul 1, 2015
Aurora's claim to recover property sold by Conrado's heirs dismissed due to laches, prescription, and insufficient evidence of fraud after 50+ years of inaction.
A

Case Digest (G.R. No. 200558)

Facts:

  • Subject Property and Initial Registration
    • A 572-sqm parcel in Brgy. Sto. Domingo, Biñan, Laguna was registered to Aquilina Martinez under TCT No. T-18729 on July 29, 1939.
    • After WWII, Aquilina and her grandmother Leoncia Almendral learned their Manila house was ruined. They borrowed money from relative Conrado Almazora to rebuild, entrusting him the owner’s duplicate of TCT No. T-18729 for safekeeping.
  • Transfer to Aurora Morales-Vivar
    • Aquilina died on July 19, 1949. As her sole heir, Aurora Morales-Vivar had TCT No. T-18729 canceled and TCT No. T-35280 issued in her name.
    • Conrado remained in possession of the property with his family and died on February 7, 1972.
  • Discovery of Transfer and Sale
    • In 1994 Aurora learned from Cristina Almazora that the title had been transferred to Conrado and sold to Fullway Development Corp. for ₱4,000,000.
    • Aurora sent letters (Oct. 30, 1995 and Mar. 5, 1996) demanding delivery of the sale proceeds; when unheeded, she filed a complaint for damages on May 9, 1996 against Cristina and Conrado’s heirs, alleging breach of trust and seeking moral and exemplary damages.
  • Proceedings Below
    • RTC Branch 259, Parañaque City: held Aurora failed to prove ownership, found laches, upheld the validity of the 1949 “Adjudication and Absolute Sale” signed by Aurora, and dismissed the complaint in its June 29, 2004 Decision.
    • CA (CA-G.R. CV 84529): in a July 28, 2011 Decision and Feb. 3, 2012 Resolution, denied petitioners’ appeal and found the suit barred by laches and by the 10-year extinctive prescription under Art. 1144, Civil Code, running from the June 17, 1965 issuance of TCT No. 35282 to Conrado.
    • Petitioners (Aurora’s heirs) elevated the case via Rule 45 petition for certiorari before the Supreme Court.

Issues:

  • Did the Court of Appeals gravely err in affirming the dismissal of Aurora’s complaint for damages?
  • Did the Court of Appeals err in not declaring the acquisition of the subject property by Conrado invalid for lack of laches?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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