G.R. No. 228680 - Spouses Sanchez vs. De Aguilar

On July 11, 2000, Juanito Aguilar sold to Spouses Francisco and Delma Sanchez a 600-sqm portion of Lot No. 71, Pls 870 in Lake Sebu, South Cotabato.
On October 23, 2004, the heirs of Aguilar (respondents) erected a fence on the northwest boundary between the spouses’ 600-sqm lot and the alleged alluvium by Lake Sebu, prompting Spouses Sanchez to file a forcible entry complaint before the Municipal Circuit Trial Court (MCTC) of Surallah-Lake Sebu.

The heirs claimed the 800-sqm area beyond the 600-sqm lot was in their actual possession, evidenced by mature trees (mahogany, lanzones, coconut, etc.), tolerated for spouses’ fish-cage operations.
On June 7, 2006, the MCTC dismissed the complaint, holding:

The spouses failed to prove prior possession over the alluvium; the heirs’ possession predated the 2000 sale.
The land was natural lake foreshore, not alluvium.
The spouses’ deed description (600 sqm) controlled over ambiguous boundaries.

On May 27, 2008, the MCTC issued a writ of execution fixing the spouses’ lot at 20 m x 30 m, using the national highway as reference; surveyor measured the highway at 60 m, heirs contended it was 30 m.
The District Engineer found the highway width to be 58.53 m; based thereon, the sheriff’s plan placed the spouses’ lot down to a 20-m public easement by the lake.
On February 17 and March 10, 2009, the Municipality of Lake Sebu, via its Zoning Office and Ad Hoc Committee on Lake Sebu Water Dispute, determined that the excess lakefront area belonged to the heirs of Aguilar, thus prioritizing their use of lake waters.

On May 22, 2010, Spouses Sanchez filed before the Regional Trial Court (RTC) a Complaint for Annulment of Judgment, seeking to annul the June 7, 2006 MCTC Decision for lack of jurisdiction or because no excess land existed.
On July 8, 2013, the RTC granted the complaint, finding:

The 58.53-m highway width reference extended the spouses’ 600-sqm lot to the lake, negating any separate alluvium.
The heirs could not have possessed a non-existent lot; the spouses were the true owners of the lakefront portion.

The MCTC had jurisdiction over persons and subject matter of the forcible entry case.
The spouses’ annulment complaint was barred by laches, having been filed four years after the MCTC Decision and more than a year after execution.

On October 10, 2016, the CA denied the spouses’ motion to dismiss the heirs’ appeal despite counsel’s MCLE non-compliance, citing an En Banc Resolution that bars dismissal for such defect.
On January 26, 2017, Spouses Sanchez filed a Rule 45 petition before the Supreme Court, reiterating their RTC-based highway-width argument.

Whether the MCTC lacked jurisdiction over the subject matter (the 600-sqm lot and alleged alluvium) or over the spouses as defendants.

Whether the spouses’ Complaint for Annulment of Judgment, filed four years after the MCTC Decision and post-execution, is barred by laches.