You are on page 1of 3

Mechielle S.

Salapang Obligations & Contracts
Case Digest: Case No. 01

G.R. No. 200558 July 1, 2015


Facts of the Case:

This case concerns a parcel of land located at Brgy. Sto. Domingo, Biñan, Laguna. It
was registered in the name of Aquilina Martinez (Aquilina) under Transfer Certificate of
Title (TCT) No. T-18729 by the Register of Deeds of Laguna on July 29, 1939.

In 1945, Aquilina and her grandmother Leoncia rebuild their house located at Tondo,
Manila by borrowing money from Conrado. In return, Leoncia entrusted to Conrado the
owner’s ducplicate copy of the property in Laguna, and Conrado and his family remained in
the said property.

Aquilina died in 1949 and the title of the said property was transferred to Aurora. In
1972, Conrado also passed away.

In 1994, Aurora learned from the widow of Conrado that the title of the property in
Laguna was long transferred to Conrado and that it has been sold to Fullway Development
Corporation by the heirs of the same.

Aurora was shocked by the news and on October 1995, she sent an demand letter to
the heirs of Conrado demanding the delivery of the payment they received for the sale of the
property, but it was unheeded.

On May 1996, Aurora and her husband filed a complaint for damages against Cristina
and the heirs of Conrado before the RTC. They said that the duplicate copy of the TCT was
given to Conrado for safekeeping. However, they admitted that Conrado has been using the
property since 1912 with the consent of Aquilina and Leoncia.

Aurora asserted that she had repeatedly asked Conrado and then Cristina but she was
ignored and that the said property was sold to Fullway without her authorization.

On June 1996, respondents filed their answer with compulsory counterclaim. They
said that the subject property was properly transferred to Conrado. They also raised the
defense that the complaint stated no cause of action and was barred by prescription. RTC then
ruled that the complaint stated a cause of action.

Respondents filed a certiorari before the Court of Appeals but was denied.

Her children substituted her after her death. Aurora had only until June 17. Petitioners moved for reconsideration. before Aurora and petitioners decided to enforce their right thereon. and not acquisitive prescription. 1965. No. 2012. Moreover. A registered land therein can never be acquired by adverse possession. it was extinctive prescription. It held that it took Aurora more than 50 years to act on Conrado’s withholding the title of the said property and petitioners were barred by laches as Aurora should have been impervious in asserting her ownership and made judicial demands to return the title and the property. Ruling: The Supreme Court denied the petition and affirmed in toto the assailed Decision and Resolution of the Court of Appeals. 1529 covers acquisitive prescription. petitioners even admitted that Conrado’s family had been staying in the subject property since 1912. The Court held that Section 47 of P. Hence. RTC further determined that the title was transferred to Conrado’s name on June 1965 by virtue of a document denominated as “Adjudication and Absolute Sale of a Parcel of Registered Land” dated January 1949 and signed by Aurora and her husband. from 1945 to 1996. Petitioners assert that they are not guilty of laches and that prescription is not a valid defense to defeat the title of Aurora in relation to PD 1529 which states that no title to registered land in derogation of the tile of the registered owner shall be acquired by prescription or adverse possession. however. pursuant to Article 1144. the Court upheld the CA’s findings that all elements for laches are present in this case. 2004 Decision. First. In their complaint. In the case at bench. It explained that Aurora was guilty of laches because for many years she slept on her right over the questioned property and failed to exhaust all means. the complaint was dismissed. Aurora appealed to the Court of Appeals. Accordingly. Second. respondents who lived all their lives in the disputed property apparently were not aware that Aurora would one day come out and claim .D. but their motion was denied by the CA in the assailed Resolution. Aurora commenced the suit only on May 12. dated February 3. However. this petition. This 10-year prescriptive period began from the time the land was registered on June 17. which barred the action of petitioners. 1996. The CA further explained that the prescriptive period to recover property obtained through fraud or mistake giving rise to an implied trust under Article 1456 of the Civil Code was 10 years. Aurora and her family entrusted to Conrado the owner’s duplicate of the certificate of title of the subject property in 1945. The Court of Appeals denied the appeal of the petitioners. In RTC’s June 29. it took five decades. legal or administrative to retrieve what was rightfully hers at the earliest possible time. 1975 within which to file her action. Third. Issue: Whether or not petitioners are barred by laches from revering the subject property.

there was no question that respondents would be prejudiced in the event that the suit would be allowed to prosper. giving rise to the situation of which complaint is made for which the complaint seeks a remedy. . or of one under whom he claims. as first prescribed by this Court in Go Chi Gun v.ownership thereon. Co Cho are as follows: (1) conduct on the part of the defendant. the complainant having had knowledge or notice. Fourth. and (4) injury or prejudice to the defendant in the event relief is accorded to the complainant. (2) delay in asserting the complainant’s rights. (3) lack of knowledge or notice on the part of the defendant that the complainant would assert the right on which he bases his suit. The four (4) elements of laches. of the defendant’s conduct and having been afforded an opportunity to institute a suit. or the suit is not held to be barred.