G.R. No. 119107 - Lagon vs. Court of Appeals

The dispute involves petitioner Sebastian Tamares (later represented by his daughter Ofelia) and respondents, the heirs of Natividad and Rafael De Guia.
The subject property is a parcel of land known as Lot 2189-B, with a total area of 2,181 square meters located in Brgy. San Agustin, Iba, Zambales.
The land is covered by Original Certificate of Title (OCT) No. 5589, originally registered in the name of Andrea De Guia.

Andrea De Guia, the original owner, was succeeded by her sole heir Saturnina Apagalang upon her death.
On January 2, 1945, Saturnina executed a Deed of Purchase and Sale for a 1,875-square meter portion of the subject property in favor of Rafael De Guia, which was duly notarized and recorded in the Notarial Registry.
After the execution of the deed, respondents – as heirs and successors of Natividad and Rafael – took possession of the 1,875-square meter lot, introduced permanent improvements (such as concrete houses and fruit-bearing trees), and consistently paid real estate taxes evidenced by tax declarations prepared in the name of Rafael.

On August 5, 1961, a subdivision survey was conducted by Magno Giron and the respondents on the subject property, which resulted in its division into Lot 2189-A (1,562 square meters) for Magno and Lot 2189-B (2,181 square meters) for respondents.
Respondents, realizing only 1,875 square meters of Lot 2189-B officially belonged to them via the Deed of Purchase and Sale, compensated Saturnina for the remaining 306 square meters by paying her P200.00.
Despite this compensation, the respondents failed to register the purchase of the 306-square meter portion with the Register of Deeds, thus never obtaining a certificate of title for that part.

On July 28, 1978, Saturnina died intestate, leaving her only son Sebastian Tamares as heir.
On June 1, 1999, approximately 21 years after Saturnina’s death, petitioner filed a complaint for unlawful detainer against respondents before the Municipal Trial Court (MTC) of Iba, Zambales.

The MTC rendered a decision on October 5, 1999, granting petitioner’s relief.
The Regional Trial Court (RTC) affirmed the MTC decision in its ruling on December 19, 2000.
The Court of Appeals (CA) in its decision dated May 20, 2002, upheld the RTC ruling, emphasizing that a Torrens title, though seemingly conclusive, may be defeated by a claim of adverse possession under certain circumstances.

On January 9, 2006, an Order of Demolition was implemented following an RTC order from December 2005.
Respondents, in subsequent litigation, filed a Complaint for Recovery of Ownership and Damages in Civil Case No. RTC-3025-I on July 27, 2010, reiterating their ownership claim based on the Deed of Purchase and Sale and their long-standing possession.

During trial, respondents presented the testimonies of key witnesses (Susan De Guia, Romeo De Guia, Cecilia P. De Guia), corroborating their continuous possession and improvements on the property.
Petitioner, represented by Ofelia Tamares Panelo, countered with allegations that the Deed of Purchase and Sale lacked probative value due to issues such as the alleged forgery of Saturnina’s signature, absence of a notarial seal, and a claim that respondents’ right was acquired by prescription.
Petitioner argued that, as a Torrens titleholder, he was entitled to unencumbered ownership and that mere possession should not override the original title.

The RTC, in its decision on October 17, 2014, ruled in favor of respondents, declaring them the rightful owners of the subject property based on the valid Deed of Purchase and Sale and witness testimonies.
Petitioner’s motion for reconsideration was denied by the RTC on December 18, 2014.
On March 23, 2017, the CA dismissed petitioner’s appeal, affirming the RTC decision by emphasizing both the validity of the Deed of Purchase and Sale and the respondents’ long and adverse possession which gave rise to acquisitive prescription.
Subsequent to the CA decision and amid ongoing proceedings, petitioner died on January 22, 2018, and his daughter Ofelia substituted him in the case.

Whether the Court of Appeals erred in upholding the validity of the Deed of Purchase and Sale as the basis for respondents’ claim of ownership over the subject property.
Whether the evidentiary presumption due to notarization and the classification of the document as an ancient document should be overruled by petitioner’s challenge, including allegations of forgery or irregularities.

Whether the CA correctly ruled that respondents had acquired the subject property by prescription – whether ordinary (requiring good faith and just title) or extraordinary (through continuous, adverse possession) – given their possession since 1945.
Whether petitioner’s delay in asserting his ownership right constitutes a bar (laches) to his claim.