Case Summary (G.R. No. 92159)
Relevant Background
On November 12, 1984, the private respondents filed a complaint in the Regional Trial Court of Tabaco, Albay, seeking recovery of possession and ownership of the land previously owned by their grandparents, Agaton Boragay and Manuela Bobiles. The private respondents asserted their claim based on the Original Certificate of Title No. RO-3334 issued in 1932 in Manuela's name. The petitioners, Jacob and Jacob, were among eight defendants, with six being declared in default.
Claims of the Respondents
The private respondents argued that after the death of Agaton and Manuela, the property passed to their only child, Gregoria Boragay. The subsequent transfer of ownership led to the issuance of Transfer Certificate of Title No. T-50318 in 1977 in the name of the private respondents.
Petitioners' Counterclaims
In defense, the petitioners contended that the land had been transferred through an Escritura de Venta Con Pacto de Retro (Deed of Sale with Right to Repurchase) from Agaton and Manuela to Leon Cabida in 1933, followed by multiple sales concluding with the registration of the property in the name of the private respondents. They claimed continuous possession of the property since then, having paid taxes on it since 1948.
Judgment of the Trial Court
Judge Oscar B. Pimentel rendered a decision on August 8, 1986, upholding the petitioners' claims by dismissing the complaint of the private respondents. The ruling concluded that the petitioners were rightful possessors of the land based on their long-term occupancy and the aforementioned sales.
Court of Appeals' Reversal
Upon appeal by the private respondents, the Court of Appeals reversed the trial court's decision. Key findings included the validity of the Certificate of Title in the name of the private respondents, which served as conclusive proof of ownership. Moreover, the court emphasized that the petitioners never contested the title's validity during the statutory period, thus losing their right to challenge it.
Legal Principles in Land Registration
The Court of Appeals maintained that under the Torrens system of land registration, a Certificate of Title is deemed incontrovertible after one year from its issuance. The petitioners' failure to oppose the registration of TCT No. 50318 constituted a bar to their claims of ownership based on the Escritura de Venta Con Pacto de Retro, even assuming its legitimacy.
Petitioners' Arguments on Bad Faith and Laches
In their appeal, the petitioners argued that the private respondents acted in bad faith and should be barred from claiming ownership under the doctrine of laches due to their delayed action. The court noted, however, that any potential laches claim was undermined by the petitioners' i
...continue readingCase Syllabus (G.R. No. 92159)
Case Background
- On November 12, 1984, the private respondents, namely Rosario Alcera Falcon, Trinidad Alcera Cruz, and Purificacion Alcera Chay, filed a lawsuit against the petitioners Ledita Burce Jacob and Buenaventura Jacob for recovery of possession and ownership of a parcel of land located in Tagas, Tabaco, Albay, covering approximately 794 square meters.
- The land was originally titled under Original Certificate of Title No. RO-3334 issued to Manuela Bobiles on June 30, 1932.
- The spouses Agaton Boragay and Manuela Bobiles had one child, Gregoria Boragay, who inherited the property upon their death. Gregoria lived on the land with her husband and children until they married and moved out.
- In 1974, third parties began constructing on the property, and in 1977, the original title was canceled, leading to the issuance of Transfer Certificate of Title No. T-50318 in the name of the private respondents.
Proceedings and Initial Claims
- The petitioners claimed ownership based on a sale made by Agaton Boragay and Manuela Bobiles to Leon Cabida in 1933, followed by a series of transfers that culminated in a verbal cession of rights to Ledita Burce Jacob in 1980.
- The petitioners asserted continuous possession of the land for over 51 years and payment of property taxes since 1948.
- Trinidad Alcera Cruz demanded the petitioners vacate the premises in May 1984, leading to the filing of the complaint in the Regional