G.R. No. L-13479 - Tiburcio vs. People's Homesite and Housing Corporation

The subject matter of the case is a parcel of land located in Quezon City, encompassing an area of about 430 hectares.
Plaintiffs, Marcelino Tiburcio et al., claim that they, along with their ancestors, have been in actual, adverse, open, public, exclusive, and continuous possession of the land since many years before March 25, 1877.
They assert that they have consistently cultivated the land, enjoyed its fruits, and paid the corresponding land taxes up to the year 1955.

In 1955, defendant People’s Homesite & Housing Corporation began asserting title to a large portion of the property, basing its claim on Transfer Certificate of Title No. 1356.
Similarly, defendant University of the Philippines claimed title over the remaining portion of the property under Transfer Certificate of Title No. 9462.
Plaintiffs argued that the inclusion of their property within the depicted technical boundaries of these titles was a clerical or mapping error and that at no time had the predecessors of the defendants exercised dominical rights over the disputed portion.

On October 11, 1957, plaintiffs filed an action for reconveyance of the disputed land before the Court of First Instance of Quezon City.
Defendant University of the Philippines filed a motion to dismiss on October 31, 1957, contending that:

The complaint did not state a cause of action.
The action was barred by the statute of limitations.
The court lacked jurisdiction over the case.
In the alternative, the defendant should be separated from the case and impleaded in a separate action.

Defendant People’s Homesite & Housing Corporation filed a motion for a bill of particulars, to which plaintiffs replied accordingly.
On November 20, 1957, Leonila G. de Perucho and Jose Penaranda attempted to intervene in the case, which was opposed by the plaintiffs.
On December 11, 1957, the trial court issued an order dismissing the complaint on two principal grounds:

Plaintiffs subsequently appealed the dismissal, asserting that the complaint, on its face, alleged sufficient facts for a valid judgment against the defendants.

Plaintiffs claimed that they were the sole heirs of Eladio Tiburcio, who died intestate in 1910, thus inheriting the land in dispute.
They maintained that despite having been in continuous possession as owners pro indiviso, the defendants acquired their respective Torrens titles in 1955 from the original owner’s predecessor-in-interest.
Plaintiffs argued that the defendants’ acquisition of title was tainted by full knowledge of their possession, negating the presumption of being innocent purchasers for value.
It was highlighted that the land had been registered under the Torrens system as early as 1914, and plaintiffs waited 43 years before resorting to judicial relief, raising issues related to laches and prescription.

Whether the facts alleged in the complaint established a valid cause of action for reconveyance despite the long lapse of time since the original possession and registration of the land.
Whether the alleged continuous adverse possession by the plaintiffs could overcome the effects of the Torrens registration.

Whether the registration of the land in 1914 and the subsequent issuance of titles in 1955 render the defendants’ claims immune to challenge.
Whether defendants, as purchasers for value, are entitled to the protection of the Torrens system irrespective of any adverse possession claims by plaintiffs.

Whether the delay of 43 years by the plaintiffs in asserting their claim constitutes laches, thereby barring the action.
Evaluation of whether the statutory one-year period for challenging a Torrens registration had long passed, making the plaintiffs’ claim untimely.

Whether the dismissal of the complaint on the basis of res judicata—taking judicial notice of the records in Land Registration Case No. L-3—is proper.
Whether the identity in subject matter and parties between the earlier registration case and the present action justifies such dismissal.