De la Calzada-Cierras v. Court of Appeals
REITERATIONFacts
The Antecedents: The core dispute concerns Lot 4362 in Pakingi, Minglanilla, Cebu. Ireneo De la Calzada, the registered owner, died in 1930, leaving a will that named his siblings as heirs. However, prior to his death, Ireneo allegedly sold the lot to his brother, Rosendo De la Calzada, in March 1930. Rosendo took possession and subsequently, in 1938, executed a document described as a Declaration of Heirs and Sale, adjudicating the lot to himself and selling half of it to Felix Sasan. Over the years, Rosendo and his heirs continued to possess the land, declared it for taxation, and paid taxes, while separate titles were eventually issued in the names of Aventino Sasan and Rosendo De la Calzada. Procedural History: The heirs of Ireneo De la Calzada's instituted heirs (the petitioners) learned of the transactions in 1981 and subsequently filed a complaint for the declaration of inexistence of fraudulent contracts and damages. The Regional Trial Court of Cebu ruled in favor of the petitioners, declaring the sale documents void and ordering the reinstatement of Ireneo's title and the cancellation of the titles held by the respondents. The private respondents appealed this decision to the Court of Appeals. The Appeal: The Court of Appeals reversed the trial court's decision, dismissing the petitioners' complaint on the grounds of laches, citing the nearly 50-year period of possession by the respondents and their predecessors without challenge from the petitioners. The appellate court found that the petitioners had slept on their rights. The petitioners, now seeking review via certiorari under Rule 45 of the Rules of Court, argue that an unregistered deed of sale does not bind registered land under the Torrens System and that their right to recover is not defeated by laches, regardless of their relationship to the original owner.
Issue(s)
Whether an unregistered deed of sale of registered land binds the land under the Torrens System. Whether the petitioners' right or cause of action is defeated by laches.
Ruling
The petition is denied for lack of merit. The assailed decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the issue of whether an unregistered deed of sale binds the land under the Torrens System: While it is true that under Section 50 of the Land Registration Act (Act No. 496), the act of registration is the operative act to convey and affect registered land, and an unregistered deed operates only as a contract between the parties, this principle cannot be invoked by the petitioners in this case. The Court of Appeals found that the conveyance of Lot No. 4362 by Ireneo De la Calzada to Rosendo De la Calzada was tangentially confirmed by Ireneo's Last Will and Testament, which did not include Lot No. 4362 among his estate. Furthermore, Rosendo De la Calzada and his successors-in-interest declared the lot for tax purposes in their names, paid taxes thereon, and remained in public, continuous, and peaceful possession thereof for almost fifty (50) years in the concept of owners, to the exclusion of others. The registration of the conveyance to Rosendo served as constructive notice to the whole world of the fact of such conveyance. On the issue of whether the petitioners' right or cause of action is defeated by laches: The Court held that the petitioners' action to recover Lot 4362 was barred by the equitable doctrine of laches. The complaint to recover the title and possession of Lot 4362 was filed only on July 21, 1981, twelve (12) years after the registration of the sale to Rosendo. The petitioners failed and neglected for an unreasonably long time to assert their right, if any, to the property in Rosendo's possession. The principle of laches is applied not to penalize neglect but to avoid recognizing a right when to do so would result in a clearly inequitable situation. The appellate court correctly relied on the pronouncement in Tambot vs. Court of Appeals that an heir may lose the right to recover property due to laches, especially when possession has been for a long period in pursuance of a sale, even if not formally approved, which the vendor never questioned during his lifetime.
Main Doctrine
An action to recover registered land, even if the conveyance was unregistered, may be barred by laches due to the claimant's unreasonable delay in asserting their right, especially when the adverse party has been in possession and paid taxes for a significant period.