Romero v. Natividad
REITERATIONFacts
The Antecedents: The underlying dispute concerns a portion of a parcel of land located at T. Claudio St., Morong, Rizal, covered by T.C.T. No. 20890, originally registered in the name of Francisca Galarosa. Petitioner Ruben Romero, Francisca's grandson, claims ownership by inheritance. Respondents Edison Natividad and Herminia Natividad-Mejorada, Francisca's great grandnephew and great grandniece, assert ownership based on a donation made by Francisca to their grandparents in the 1920s, followed by continuous possession and inheritance through their father. The core of the dispute lies in conflicting claims of ownership and possession stemming from alleged inheritance and a donation, with respondents constructing a building on the disputed portion. Procedural History: Petitioner Ruben Romero initiated this action by filing a complaint for recovery of possession and quieting of title against respondents in the Regional Trial Court (RTC) at Morong, Rizal, in the latter part of 1996. The RTC, in its decision dated June 15, 2001, dismissed petitioner's complaint, ruling in favor of the respondents and declaring them owners of the disputed lot due to acquisitive prescription based on their long and uninterrupted possession. Petitioner appealed this decision to the Court of Appeals (CA). The CA, in its decision dated August 29, 2003, affirmed the RTC's ruling but modified it by deleting the award of attorney's fees. Petitioner's subsequent motion for reconsideration was denied by the CA in a resolution dated January 29, 2004. The Petition: This case is before the Supreme Court on a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the decision and resolution of the Court of Appeals. Petitioner argues that the appellate court erred in affirming the trial court's decision based on prescription, contending that prescription cannot operate against a titled property. He also challenges the validity of the donation, asserting it was not in a public document, and disputes the extent of respondents' predecessors' possession. The petitioner seeks the reversal of the CA's decision and resolution, asserting his rightful ownership and possession of the property.
Issue(s)
Whether the respondents, through their predecessors-in-interest, acquired ownership of the disputed property by acquisitive prescription and laches despite the property being covered by a Torrens title. Whether the petitioner and his predecessor-in-interest were barred by laches from recovering possession and ownership of the property.
Ruling
The petition is denied, and the assailed decision and resolution of the Court of Appeals are affirmed. The law aids the vigilant, not those who sleep on their rights.
Ratio Decidendi
On the issue of acquisitive prescription and laches against a titled property: The Supreme Court affirmed the Court of Appeals' ruling that the general rule that prescription does not operate against a titled property does not apply when the person invoking it is not the registered owner. In this case, neither the petitioner nor his predecessors-in-interest were the registered owners of the disputed portion of the land. The Court emphasized that respondents and their predecessors-in-interest had been in open, continuous, and uninterrupted possession of the subject parcel of land since the 1920s, a period of approximately seventy-four years before petitioner filed his complaint in 1994. This prolonged possession, coupled with the petitioner's and his predecessor-in-interest's inaction for decades, led the Court to apply the doctrine of laches. The Court cited jurisprudence, such as Tambot, et al. v. Court of Appeals, et al., which held that continuous, open, and adverse possession for more than thirty-six years as owner can lead to acquisition of title through prescription, and that the registered owner's title is not protected by Section 46 of the Land Registration Act if the petitioners are not the registered owners. The Court reiterated that laches, the essence of which is the neglect to assert a right over a long period of time, may prevent recovery of a titled property, even if the mode of transfer was invalid, as in the case of Heirs of Batiog Lacamen vs. Heirs of Laruan and Mejia de Lucas vs. Gamponia. On the issue of whether the petitioner and his predecessor-in-interest were barred by laches: The Supreme Court found that the petitioner and his deceased mother, Estelita, had "slumbered on their perceived rights for seventy (70) years." The Court noted that while Estelita may have filed a case against Demetrio Natividad in 1965, this was 44 years after Demetrio first occupied the property in the early 1920s, and this case was dismissed by agreement. Furthermore, from 1965 until 1996, when the present case was filed, a period of 26 years elapsed without any further legal action. The Court contrasted this with the case of Mateo vs. Diaz, where the petitioners took steps to assert their rights immediately after discovering the existence of their father's title. The Court concluded that the "neglect to assert ownership for a long period of time acts as a bar to the present action," applying the legal precept "Vigilantibus sed non dormientibus jura subverniunt" – the law aids the vigilant, not those who sleep on their rights. This prolonged inaction and neglect converted what might have been a valid claim into a stale demand.
Main Doctrine
The doctrine of laches may bar recovery of a titled property, even if the mode of transfer was invalid, especially when the claimant and their predecessors-in-interest have slept on their rights for an extended period, while the adverse possessors have occupied the property openly, continuously, and in concept of owner for decades.