Case Summary (G.R. No. 234392)
Factual Background
In 1945 the petitioners permitted respondent’s family to occupy the land rent-free, on condition of vacating upon demand. The respondent’s family built a nipa hut and remained on the premises without paying realty taxes until 1984.
Alleged Oral Sale
Respondent asserts that in the early 1960s petitioner Victoria’s mother orally sold her a 100-sqm portion for ₱2,000, fully paid by 1962. No deed, receipt or title transfer was executed; tax declarations continued to name the petitioners.
Procedural History
– Aug. 1996: Petitioners gave respondent a written demand to vacate.
– Feb. 1997: Petitioners filed ejectment before the MCTC, which dismissed on laches.
– RTC reversed, ordering ejectment and removal of improvements.
– Court of Appeals reinstated MCTC decision.
– Petitioners sought Supreme Court review under Rule 45.
Legal Issue
Whether registered owners may eject an occupant with mere toleration rights who claims ownership by unproven oral sale and invokes laches or good-faith improvements.
Applicable Law
– Rule 70, Sec. 1: Unlawful detainer arises when permissive possession continues after demand.
– Torrens doctrine (PD 1529 §48): Certificates of title are indefeasible and not subject to collateral attack.
– Civil Code Arts. 448, 546, 548: Rights of good-faith possessors regarding improvements; inapplicable to tolerated occupants.
Ownership and Possession
Torrens title conclusive proof of ownership and carries the right to possess. Respondent’s toleration-based occupation became unlawful upon petitioners’ demand, supporting ejectment.
Oral Sale Analysis
Respondent’s failure to furnish contemporaneous evidence or to assert the sale when first demanded undermines her claim. Torrens title prevails over unproven, extrinsic oral agreements.
Laches Doctrine
A registered owner’s right to recover possession is imprescriptible and not extinguished by laches. Petitioners acted promptly after demand; respondent’s decades-long delay in formalizing her alleged interest demonstrates lack of diligence.
Improvements and Good Faith
Respondent was aware her occupancy was by mere permission; she could not be a good-faith possessor en
Case Syllabus (G.R. No. 234392)
Facts of the Case
- Petitioners Marcos R. Esmaquel and Victoria Sordevilla are the registered owners of a 253-square-meter parcel of land in Barangay San Miguel, Majayjay, Laguna, covered by TCT No. T-93542.
- In 1945, the petitioners allowed respondent Maria V. Coprada and her family to occupy the land rent-free and to construct a residential house, on the condition that they vacate upon demand.
- The petitioners never enforced eviction earlier due to respondent’s family circumstances; respondent and her eight children had no other home.
- Over the years respondent paid real property taxes in the petitioners’ names, beginning in 1984. Some of her children later improved their financial capacity, and respondent herself acquired a separate house.
- Verbal demands and a written notice dated August 22, 1996, giving respondent until November 30, 1996 to vacate, went unheeded. A barangay conciliation failed, and petitioners filed an ejectment complaint in the 2nd MCTC of Magdalena, Laguna on February 24, 1997.
Procedural History
- MCTC (Sept. 11, 1997) dismissed the ejectment complaint, finding petitioners barred by laches and respondent’s unchallenged oral acquisition of the lot.
- RTC, Branch 26, Santa Cruz, Laguna (Nov. 24, 1998) reversed the MCTC, declaring petitioners’ registered title and tolerance-based possession sufficient to sustain ejectment; ordered respondent to vacate and remove improvements.
- CA (April 6, 2001) reversed the RTC and reinstated the MCTC decision; denied petitioners’ subsequent motion for reconsideration in a Resolution dated February 15, 2002.
- Petitioners sought certiorari review before the Supreme Court under Rule 45, raising issues on Torrens title, laches, unproven oral sale, and collateral attack.
Issues Presented
- Whether the right of registered owners to recover possession is barred by laches.
- Whether an unregistered, unproven oral sale can defeat Torrens ownership and right to eject.
- Whether respondent’s occupation became unlawful upon demand, thereby permitting summary ejectment.
- Whether the petitioners’ Torrens title is immune from collateral attack.
Petitioners’ Contentions
- They hold an indefeasible Torrens title (TCT No. T-93542) and thus an imprescriptible right to eject any unauthorized occupant.
- Respondent’s claim of a 1962 oral sale is unproven, belated, and a mere afterthought.