Alarcon v. Bidin
REITERATIONFacts
The Antecedents: Petitioners filed an action for Recovery of Possession of Real Property with Damages concerning Lot 3178. The property was registered under Original Certificate of Title No. T-13, 125 in the names of Roberto Alarcon (father of petitioners) and Guillerma Trinidad. In 1923, Roberto Alarcon leased the property to Esteban Sergas, predecessor-in-interest of private respondents. On January 5, 1926, Roberto Alarcon allegedly sold a portion of his share to Esteban Sergas, with the sale inscribed on May 3, 1963. The deed of sale, however, bore the name "Alberto Alarcon" as vendor, though Roberto Alarcon's thumbmark appeared. On July 9, 1928, Roberto Alarcon sold another portion of his share to Adela Alvarez, who later sold it to Domingo Rojas Francisco. Petitioners denied the genuineness of these deeds of sale, alleging the thumbmark was not Roberto Alarcon's and he was not "Alberto" Alarcon. Procedural History: Petitioners filed suit on October 23, 1978. Private respondents moved to dismiss based on the statute of limitations and laches. Petitioners opposed, arguing no prescription could lie against their father's recorded title. The Regional Trial Court dismissed the complaint on May 23, 1979, for being barred by laches, and denied reconsideration on August 27, 1979. The Petition: Petitioners assail the dismissal orders.
Issue(s)
Whether the dismissal of the complaint on the ground of laches was proper. Whether the action for recovery of possession is barred by prescription or laches, despite the property being registered under the Torrens System.
Ruling
The Supreme Court sustained the Orders of the respondent Judge dismissing the complaint. The petition was denied for lack of merit.
Ratio Decidendi
On the propriety of dismissal due to laches: The Court affirmed the dismissal, finding that petitioners and their predecessors-in-interest were guilty of laches. From the date of sale in favor of Esteban Sergas in 1926, he and his successors-in-interest possessed the property adversely. Similarly, Adela Alvarez took possession from 1928 until she sold her portion in 1954 to Domingo Rojas Francisco, who has also been in uninterrupted possession. The vendor, Roberto Alarcon, took no steps to rescind the sales or recover the property from his death in 1960 until the suit was filed in 1978, a period of at least 18 years. Petitioners themselves waited over 50 years from the execution of the deeds of sale. This prolonged passivity and inaction converted their cause of action into a stale demand, as held in Mejia de Lucas vs. Gamponia. On prescription and the Torrens System: While it is true that land registered under the Torrens System cannot be acquired by prescription or adverse possession, the protection afforded by the law is for registered owners. In this case, the sale to Esteban Sergas was inscribed in 1963, technically making him the owner of his portion from that date. Furthermore, if the cause of action was predicated on fraud, it had prescribed, not having been brought within four years from the inscription of the deed of sale in 1963. Laches, however, is a distinct equitable defense that bars stale claims regardless of the Torrens title, and it was properly invoked by the respondents.
Main Doctrine
The dismissal of a complaint based on laches is proper when the plaintiffs and their predecessors-in-interest have been guilty of unreasonable delay and inaction in asserting their claim over the property, rendering their cause of action a stale demand, even if the property is registered under the Torrens System.