Esmaquel v. Coprada
REITERATIONFacts
The Antecedents: Petitioners, spouses Marcos and Victoria Esmaquel, filed an ejectment case against respondent Maria Coprada for the recovery of possession of a parcel of land registered under their name. Petitioners alleged that they allowed respondent to occupy the land in 1945 for residential purposes, with the understanding that she would vacate upon demand. Respondent's circumstances improved, prompting petitioners to demand she vacate, which she refused. Respondent, however, claimed that the land was orally sold to her in 1962 by petitioner Victoria's mother, Emiliana Coprada, and that she had paid the purchase price and realty taxes since then, building a semi-concrete structure on the land. She argued that petitioners' claim was barred by laches and that she was a builder in good faith. Procedural History: The Municipal Circuit Trial Court (MCTC) dismissed the ejectment case, finding that laches had set in against petitioners. The Regional Trial Court (RTC) reversed the MCTC, ruling that respondent's possession was by tolerance and became unlawful upon demand to vacate. The RTC found the oral sale unproven and ordered respondent to vacate. The Court of Appeals (CA) reinstated the MCTC decision, granting respondent's petition. Petitioners then filed the instant petition for review on certiorari. The Petition: Petitioners sought to set aside the CA's decision, arguing that the right of registered owners to recover possession is never barred by laches, that an unproven oral sale cannot defeat a Torrens title, and that laches had set in against respondent, not them. They also contended that the certificate of title cannot be subject to collateral attack.
Issue(s)
Whether the right of registered owners to recover possession of their property is barred by laches. Whether an unproven oral sale can defeat the registered owner's right to possession. Whether the respondent's claim of being a builder in good faith is tenable. Whether the respondent's occupation of the property became unlawful after demand to vacate.
Ruling
The petition is meritorious. The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals, and REINSTATED the Decision of the Regional Trial Court. The dispositive portion states: "WHEREFORE, the petition is GRANTED. The Decision and the Resolution of the Court of Appeals, dated April 6, 2001 and February 15, 2002, respectively, in CA-G.R. SP No. 49994, affirming the Decision of the 2nd Municipal Circuit Trial Court in Civil Case No. 1875, are REVERSED and SET ASIDE. The Decision of the Regional Trial Court of Santa Cruz, Laguna, Branch 26, in Civil Case No. SC-3580, is REINSTATED."
Ratio Decidendi
On whether the right of registered owners to recover possession is barred by laches: The Court held that the right of a registered owner to eject any person illegally occupying their property is imprescriptible and cannot be barred by laches. The Court cited Gaudencio Labrador v. Spouses Perlas, which reiterated the ruling in Bishop v. Court of Appeals, stating that lawful owners have the right to demand the return of their property at any time as long as the possession was unauthorized or merely tolerated. In this case, respondent's occupation was by mere tolerance, and petitioners acted promptly by sending a demand letter and filing a complaint after the demand was ignored, thus they were not guilty of laches. On whether an unproven oral sale can defeat the registered owner's right to possession: The Court found that respondent failed to present sufficient evidence to substantiate her claim of an oral sale in 1962. Crucially, she did not mention the alleged sale in her reply to the demand letter to vacate, indicating it was a mere afterthought. The Court emphasized that as against an unproven claim of oral sale, the Torrens title of the petitioners must prevail, as it serves as evidence of indefeasible and incontrovertible ownership and the right to possession. The Court reiterated that respondent's argument of having acquired ownership of a portion of the land through sale constitutes a collateral attack on the petitioners' Torrens title, which is not allowed under Section 48 of Presidential Decree No. 1529. The validity of a certificate of title can only be assailed in a direct proceeding for that purpose, not in an ejectment case. On whether the respondent's claim of being a builder in good faith is tenable: The Court ruled that respondent's argument of being a builder in good faith is without merit. Articles 448 and 546 of the Civil Code, which allow reimbursement of useful improvements and retention of the premises, apply only to a possessor in good faith, one who builds with the belief of being the owner. Since respondent's occupation was by mere tolerance, she knew her possession could be terminated anytime and thus cannot be considered a builder in good faith. Her reliance on paying realty taxes was also unavailing as she only started in 1984 and the declared owner was petitioner Victoria. On whether the respondent's occupation became unlawful after demand to vacate: The Court affirmed that respondent's possession, which was initially by tolerance, became unlawful when she refused to vacate the premises after petitioners made a verbal demand and sent a formal demand letter. In unlawful detainer cases, possession that was originally legal becomes illegal upon the demand to vacate and the refusal to do so, making summary ejectment the proper remedy.
Main Doctrine
The right of a registered owner to recover possession of their property is imprescriptible and cannot be barred by laches, even if the possession of the occupant was initially by tolerance. A claim of oral sale, especially when not raised promptly, is insufficient to defeat a Torrens title, and challenging the title in an ejectment case constitutes a prohibited collateral attack.