Declaro v. Court of Appeals
REITERATIONFacts
The Antecedents: Luciano Comorro and Dominga Dordas had seven children. After Dominga's death, Luciano married Matea Diaz and had three children, including Felomino and Altesima. Luciano and Matea owned Lot No. 1470. Luciano died intestate in 1949, followed by Matea in 1959. On January 5, 1960, Felomino and Altesima executed a "Confirmation of a Deed of Absolute Sale" in favor of Enrique and Gregoria Diaz, stating that Luciano had sold Lot No. 1470 to them in 1934, but the original deed was lost. This confirmation was registered, leading to the cancellation of Original Certificate of Title (OCT) No. RO-4075 (13103) in the names of Luciano and Matea, and the issuance of Transfer Certificate of Title (TCT) No. 5374 in the name of Gregoria Diaz. Procedural History: In 1990, the heirs of Luciano Comorro (petitioners) filed a civil complaint for reconveyance of Lot No. 1470 against the heirs of Gregoria Diaz (respondents). The Regional Trial Court (RTC) ruled in favor of the petitioners, declaring them co-owners, nullifying the "Confirmation of a Deed of Absolute Sale," ordering the cancellation of TCT No. T-5374 and reinstatement of OCT No. RO-4075 (13103), and directing partition. The RTC held that the "Confirmation" was null and void due to lack of evidence of the original sale and that prescription and laches did not apply to actions for declaration of inexistence of a contract. On appeal, the Court of Appeals (CA) reversed the RTC decision, dismissing the complaint for reconveyance, finding the "Confirmation" valid, and holding that respondents had established open, continuous, and exclusive possession. The Petition: Petitioners assail the CA decision, arguing it erred in setting aside the RTC judgment and dismissing their complaint, contending that the transfer of the property to Gregoria Diaz was invalid due to the unproven existence of the original sale.
Issue(s)
Whether there was a valid transfer of Lot No. 1470 to Gregoria Diaz. Whether petitioners' action for reconveyance is barred by prescription and laches.
Ruling
The petition is DENIED. The assailed decision of the Court of Appeals dated March 31, 1995, is AFFIRMED. Costs against petitioners.
Ratio Decidendi
On the issue of valid transfer of Lot No. 1470 to Gregoria Diaz: The Court affirmed the appellate court's finding that the "Confirmation of a Deed of Absolute Sale" was a valid instrument attesting to the sale of the land by Luciano and Matea to Gregoria Diaz. As a public document, it carries the presumption of regularity, which was not convincingly rebutted by the petitioners. Furthermore, the "Confirmation" was executed by Felomino and Altesima, who were heirs of Luciano and Matea, and it constituted a declaration against their own self-interest, as confirming the sale would reduce their hereditary shares. This declaration against interest is taken as favoring the truthfulness of its contents. The registration of this "Confirmation" on May 23, 1960, and the subsequent issuance of TCT No. T-5374 in the name of Gregoria Diaz on the same day, served as constructive notice to the whole world of the transfer of the property. On the issue of whether petitioners' action for reconveyance is barred by prescription and laches: The Court ruled that petitioners' action for reconveyance was barred by laches and prescription. An action for reconveyance must be filed within ten years from the issuance of the title, as such issuance operates as constructive notice. In this case, the petitioners filed their complaint on May 7, 1990, thirty years after the registration of the "Confirmation" and the issuance of TCT No. T-5374 in 1960. The Court found that the petitioners had unjustifiably slept on their rights for an unreasonably long period, failing to assert their claim despite knowing about the "Confirmation" as early as 1968, according to Expectacion Declaro's testimony. Petitioner Ludovico Degala also testified that they had asked for their share from Gregoria immediately after the war, indicating awareness of her claim. The fact that respondents had been in open, continuous, and exclusive possession of the property, even erecting houses thereon, further strengthened the claim of laches. Therefore, petitioners are estopped from questioning the validity of respondents' title.
Main Doctrine
The registration of a deed of sale, even if based on a 'Confirmation of a Deed of Absolute Sale' which is a public document enjoying presumption of regularity and constituting a declaration against interest, serves as constructive notice to the whole world. Failure to file an action for reconveyance within the ten-year prescriptive period from the issuance of the title, coupled with unjustifiable delay and inaction, constitutes laches, barring the claim.