Heirs of Yadao v. Heirs of Caletina
REITERATIONFacts
The Antecedents: Respondents, heirs of Juan Caletina, filed a complaint for ownership and recovery of possession of Lot 1087, covered by OCT No. P-479(S), against petitioners' predecessors-in-interest. Respondents claimed to be the grandchildren and heirs of Juan, the registered owner. Petitioners' predecessors-in-interest claimed to have bought Lot 1087 on September 28, 1962, from Juan's surviving heirs, evidenced by an unnotarized Contrata and a notarized Deed of Absolute Sale dated October 15, 1962. They asserted continuous possession since 1962. Procedural History: The Regional Trial Court (RTC) initially dismissed the complaint for lack of jurisdiction but later reinstated it. The RTC ruled in favor of respondents, declaring them owners and ordering the restoration of possession. The Court of Appeals (CA) affirmed the RTC's decision. The RTC and CA found no evidence of sale, deemed the Contrata unenforceable due to lack of notarization, and the Deed of Sale void as Casiana Dalo, the seller, was not a legal heir. They also ruled that prescription and laches do not apply to registered lands. The Petition: Petitioners sought reversal, arguing lack of jurisdiction, prescription of respondents' action, validity of the sale documents, and acquisition of ownership through prescription. Respondents countered that petitioners were estopped from questioning jurisdiction, acquisitive prescription is unavailing, and the sale documents were void.
Issue(s)
Whether the trial court had jurisdiction over the subject matter. Whether petitioners acquired ownership of the subject lot through acquisitive prescription. Whether respondents' action is barred by extinctive prescription. Whether there was a valid and binding contract selling Lot 1087 to the Yadaos.
Ruling
The petition is GRANTED. The Decision dated February 29, 2016, and Resolution dated December 20, 2016, of the Court of Appeals are REVERSED and SET ASIDE. The complaint in Civil Case No. 1868-S is ordered DISMISSED. Petitioners are declared co-owners of Lot 1087. Respondents are DIRECTED to execute a registrable deed of conveyance in petitioners' favor. If respondents refuse, the Clerk of Court is authorized to execute such document.
Ratio Decidendi
On the issue of jurisdiction: The Court held that petitioners are estopped from questioning the jurisdiction of the RTC over the subject matter. Citing Tijam v. Sibonghanoy, the Court explained that estoppel by laches may bar a party from invoking lack of jurisdiction when the issue is raised late in the proceedings after active participation in the trial. Petitioners raised the issue of jurisdiction 16 years after the complaint was filed and when the trial was nearing its end, despite being aware of the assessed value from the start. This belated claim was deemed inefficient and iniquitous. On acquisitive prescription: The Court reiterated that Section 47 of PD 1529 prohibits acquiring title to registered land by prescription or adverse possession. Ownership and possession of registered land cannot be obtained or acquired by prescription, regardless of the length of physical occupation. Therefore, petitioners could not have acquired Lot 1087 through acquisitive prescription. On extinctive prescription: The Court clarified that while acquisitive prescription does not apply to registered land, extinctive prescription can bar the registered owner or their heirs from recovering possession if the action is filed beyond the prescriptive period. The Court found that respondents' action, filed on June 22, 1993, was filed more than 31 years after the sale and possession by petitioners' predecessors-in-interest on September 28, 1962. This lapse of time barred respondents from seeking relief from the courts, as the law aids the vigilant, not those who slumber on their rights. On the validity of the contract: The Court disagreed with the lower courts' finding that the Contrata was unenforceable due to lack of notarization. Citing Article 1358 of the Civil Code and established jurisprudence, the Court held that the failure to observe the form prescribed for public documents does not invalidate the contract; it is merely for convenience. An unnotarized sale is valid and enforceable between the parties and their heirs. Furthermore, the Court noted that Dolores, respondents' own witness, admitted the sale of Lot 1087 to petitioners' predecessors. The delivery of the owner's duplicate copy of OCT No. P-479(S) and the petitioners' open and continuous possession of the entire lot for over 30 years without objection further supported the validity of the sale. The Court also found that Casiana Dalo could not have validly sold the property as she was not a legal heir of Juan Caletina, but this did not invalidate the sale executed by other heirs, specifically Hospicio, Sr., who was a signatory to the Contrata and a legal heir. The Court concluded that the series of sales to petitioners' predecessors were valid and enforceable, and respondents were barred by extinctive prescription from assailing them.
Main Doctrine
The Court held that while acquisitive prescription cannot be invoked against a registered owner, extinctive prescription can bar even the registered owner from recovering possession if the action is filed beyond the prescriptive period. Furthermore, an unnotarized deed of sale, while a private document, is valid and enforceable between the parties and their heirs, and the delivery of the owner's duplicate copy of the title, coupled with open and continuous possession for over thirty years without objection, strengthens the claim of ownership.