Case Summary (G.R. No. 200558)
Petitioner
Consuelo V. Pangasinan, Lucio M. Vivar, and Annabella V. Borromeo, substituting for their mother Aurora Morales-Vivar, seeking damages and recovery of proceeds from the sale of the subject property.
Respondents
Cristina Disonglo-Almazora and other heirs of Conrado Almazora, who acquired registered title to the land and sold it to Fullway Development Corporation.
Key Dates
• July 29, 1939: TCT No. T-18729 issued to Aquilina Martinez.
• July 19, 1949: Aquilina’s death; TCT No. T-35280 issued to Aurora.
• June 17, 1965: TCT No. 35282 issued to Conrado via a 1949 “Adjudication and Absolute Sale” deed.
• May 9, 1996: Complaint for damages filed.
• June 29, 2004: RTC dismissed complaint.
• July 28, 2011: CA affirmed dismissal.
• July 1, 2015: Supreme Court decision affirming CA.
Applicable Law
• 1987 Constitution (post-1990 decision)
• Rule 45, Rules of Court (certiorari)
• Civil Code provisions on laches (equity doctrine), extinctive prescription (Art. 1144), and constructive trust (Art. 1456)
• PD No. 1529 Sec. 47 (registered land not subject to acquisitive prescription)
Facts
After WWII, Aquilina and her grandmother Leoncia entrusted the owner’s duplicate title to Conrado to finance home reconstruction. Conrado’s family continuously occupied the Laguna parcel. In 1949, Aurora and her husband signed an “Adjudication and Absolute Sale” purporting to convey the land to Conrado, but the authenticity of that instrument was never disputed. Title transfers culminated in sale to Fullway for ₱4 million by Conrado’s heirs.
Procedural History
Aurora (joined by husband) filed for damages in 1996, alleging the duplicate title was only for safekeeping and that respondents misappropriated sale proceeds. Respondents countered with proper title transfers and raised laches and prescription. The RTC dismissed for lack of proof and laches. The CA affirmed, applying a 10-year extinctive prescription and laches for a 50-year delay. Substitution of parties occurred upon Aurora’s death. Petitioners sought certiorari relief before the Supreme Court.
Issues
- Whether laches barred the action.
- Whether prescription extinguished petitioners’ right.
- Whether fraud was proven to establish an implied constructive trust.
Supreme Court Ruling
The petition under Rule 45 raised factual questions (laches, prescription, bad faith), beyond pure questions of law; thus, it was dismissible on jurisdictional grounds. On the merits, the Court affirmed the lower courts:
Examination of Laches
Laches requires (1) defendant’s conduct, (2) complainant’s delay after knowledge, (3) defendant’s lack of notice of an imminent claim, and (4) prejudice to defendant. Here, petitioners waited almost 50 years (1945–1996) before asserting rights. Respondents had no reason to anticipate litigation, and they would be prejudiced by belated claims. Two unspecific demand letters in 1995–1996 did not overcome the prolonged inaction. Equity disfavors “sleepers” on their rights.
Prescription of Actions
While PD 1529 Sec. 47 bars acquisitive prescription of registered land
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Facts
- The subject property is a 572-square-meter parcel in Brgy. Sto. Domingo, Biñan, Laguna, originally registered under TCT No. T-18729 in the name of Aquilina Martinez on July 29, 1939.
- After World War II, Aquilina and her grandmother Leoncia Almendral borrowed money from their relative Conrado Almazora to rebuild a ruined house, entrusting him the duplicate copy of TCT No. T-18729 for safekeeping. Conrado’s family thereafter occupied the Laguna property.
- Aquilina died on July 19, 1949; her daughter Aurora Morales-Vivar inherited the land, leading to the issuance of TCT No. T-35280 in her name and cancellation of TCT No. T-18729.
- Conrado died in 1972. In 1994, Aurora learned from Cristina Almazora that the property had been transferred to Conrado and sold to Fullway Development Corporation for ₱4,000,000 without her consent.
- Aurora sent demand letters (October 30, 1995 and March 5, 1996) to the Almazora heirs for the proceeds of sale; these were ignored.
- On May 9, 1996, Aurora and her husband Arturo filed a complaint for damages, asserting (a) the duplicate title was held in trust, (b) repeated but unheeded demands for its return, (c) the sale was unauthorized, and (d) prayer for moral and exemplary damages.
Procedural History
- Respondents answered with a compulsory counterclaim, alleging valid transfers to Conrado (TCT No. T-35282) and subsequently to his heirs (TCT No. T-114352), and raising defenses of no cause of action, prescription, and the non-transmissibility of claimed fraud.
- The RTC denied respondents’ special and affirmative defenses in an interlocutory order which the CA upheld in a certiorari petition, ruling that the action for damages arose from trust-related fraud and was not clearly time-barred.
- Trial on the merits ensued; Aurora and Arturo adduced evidence but filed no memorandum, while respondents did.
- On June 29, 2004, the RTC dismissed the complaint for lack of proof and due to laches, finding the 1949 “Adjudication and Absolute Sale” deed genuine and A