Tamares v. Heirs of De Guia
REITERATIONFacts
The Antecedents: The controversy involves Lot 2189-B, covered by OCT No. 5589 registered in the name of Andrea De Guia. Andrea's heir, Saturnina Apagalang, sold a 1,875-square meter portion to Rafael De Guia (married to Natividad) on January 2, 1945, via a Deed of Purchase and Sale. Respondents, as heirs of Rafael and Natividad, took possession of this portion, introduced improvements, and paid taxes. Later, they purchased an additional 306 square meters from Saturnina, but failed to register this purchase. Magno Giron also purchased a portion of the land. Respondents' possession of 1,875 square meters encroached on the remaining 306 square meters. Procedural History: In 1999, petitioner Sebastian Tamares (heir of Saturnina) filed an unlawful detainer case, which was affirmed by the MTC, RTC, and CA. An order of demolition was implemented in 2006. Subsequently, respondents filed a Complaint for Recovery of Ownership and Reconveyance with Damages. The RTC dismissed their initial complaint for lack of jurisdiction. In a subsequent complaint (Civil Case No. RTC-3025-I), the RTC ruled in favor of respondents, declaring them owners of the 2,181 square meter lot. The CA affirmed this decision, holding that respondents were owners based on the Deed of Purchase and Sale and had acquired the property by prescription. Petitioner appealed to the Supreme Court. The Petition: Petitioner argued that his Torrens title should prevail over respondents' claim of ownership through possession. The Supreme Court considered whether the CA erred in upholding the validity of the Deed of Purchase and Sale and in ruling that respondents acquired the property by prescription.
Issue(s)
Whether the Court of Appeals gravely erred when it upheld the validity of the Deed of Purchase and Sale as the basis of respondents' ownership of the property. Whether the Court of Appeals gravely erred when it ruled that respondents had already acquired the subject property by acquisitive prescription, but the petitioner is barred by laches.
Ruling
The petition is DENIED. The Decision dated March 23, 2017 and the Resolution dated July 27, 2017 of the Court of Appeals in CA-G.R. CV No. 104712 are AFFIRMED.
Ratio Decidendi
On the validity of the Deed of Purchase and Sale: The Court affirmed the CA's ruling that respondents have a better right to the property based on the Deed of Purchase and Sale dated January 4, 1945. The Court reiterated that while a Torrens title is strong evidence of ownership, it does not make the holder the absolute owner if they have voluntarily disposed of their rights. The Deed of Purchase and Sale, being duly notarized, enjoys a prima facie presumption of authenticity and due execution. Petitioner failed to present clear, positive, and convincing evidence to overcome this presumption, with his bare denial being insufficient. Furthermore, the Deed qualified as an ancient document, being over 30 years old, produced from proper custody, and unblemished, thus requiring no further proof of authenticity. The Court also dismissed petitioner's claim that Saturnina was not in a position to sell, deeming it a factual issue inappropriate for a Rule 45 petition. On acquisitive prescription and laches: The Court disagreed with the CA's conclusion that respondents acquired the property by prescription. Citing Section 47 of Presidential Decree No. 1529 (Property Registration Decree), the Court stated that no title to registered land in derogation of the registered owner can be acquired by prescription or adverse possession. However, the Court found that petitioner was barred by the equitable presumption of laches. Petitioner, not being the lawful or registered owner, neglected to assert his alleged ownership for an unreasonable length of time (54 years) by filing an ejectment case only in 1999. The Court emphasized the principle of vigilantibus sed non dormientibus jura subveniunt, meaning the law aids the vigilant, not those who sleep on their rights. Despite not acquiring ownership by prescription, respondents were deemed to have a better right by virtue of the Deed of Purchase and Sale, and petitioner's claim was barred by laches.
Main Doctrine
While a Torrens title is conclusive evidence of ownership, it does not shield a holder in bad faith. A registered owner may lose the right to recover property through laches, especially when they have voluntarily disposed of their rights over the land. Prescription cannot be acquired against a registered owner under PD 1529, but laches can bar an heir from asserting ownership after an unreasonable delay.