G.R. No.

L-29788 August 30, 1972

RAFAEL S. SALAS, et. al,

vs.
HON. HILARION U. JARENCIO, et. al

Facts:
City of Manila owner in fee simple of a parcel of land known as Lot 1, Block 557 of
Cadastral Survey of City of Manila, containing an area of 9689.80 sqm. On various dates in 1927,
City of Manila sold portions of the parcel of land. When the last sale was effected August 1924,
Transfer Certificate of Title 22547 covering the residue of the land 7490.10 sam was issued in
the name of City of Manila.
On September 1960, Municipal Board of Manila adopted a resolution requesting the
President to consider the feasibility of declaring the land under Transfer Certificate of Title
25545-25547 as patrimonial property of Manila for the purpose of selling these lots to the
actual occupants thereof. The bill became Republic Act 4118, converting the land from
communal property to disposable and alienable land of State.
City of Manila, for some reasons, brought an action to restrain, prohibit, and enjoin Land
Authority and Register of Deeds from implementing RA 4118, and praying for the declaration of
RA 4118 as unconstitutional.
Trial court declared RA 4118 to be unconstitutional and invalid on the ground that it
deprived City of its property without due process of law and payment of just compensation.
Land Authority and Register of Deeds argued that the land is a communal land, or a
portion of public domain owned by State; that the land has not been used by City of Manila for
any public purpose; that it was originally a communal land not because it was needed in
connection with its organisation as a municipality but rather for the common use of its
inhabitants; that the City mayor merely enjoys the usufruct over said land and its exercise of
acts of ownership by selling parts thereof did not necessarily convert the land into a patrimonial
property of City of Manila nor divert the State of its paramount title.
Issue:
Whether the aforementioned land is a private or patrimonial property of the City of Manila.
Held:
The land is public property.
As a general rule, regardless of the source or classification of the land in the possession
of municipality, excepting those which it acquired in its own funds in its private or corporate
capacity, such property is held for the State for the benefit of its inhabitants, whether it be for
governmental or proprietary purposes. The legal situation is the same if the State itself holds
the property and puts it to a different use.
When it comes to property of municipality which it did not acquire in its private or
corporate capacity with its own funds, the legislature can transfer its administration and
disposition to an agency of the National Government to be disposed of according to its
discretion. Here it did so in obedience to the constitutional mandate of promoting social justice
to insure the well-being and economic security of the people.
The property was not acquired by the City of Manila with its own funds in its private or
proprietary capacity. The land was part of the territory of City of Manila granted by sovereign in
its creation. Furthermore, City expressly recognised the paramount title of the State over its
land when it requested the President to consider the feasibility of declaring the lot as
patrimonial property for selling.
There could be no more blatant recognition of the fact that said land belongs to the
State and was simply granted in usufruct to the City of Manila for municipal purposes. But since
the City did not actually use said land for any recognized public purpose and allowed it to
remain idle and unoccupied for a long time until it was overrun by squatters, no presumption of
State grant of ownership in favor of the City of Manila may be acquiesced in to justify the claim
that it is its own private or patrimonial property.

PIONEER INSURANCE AND SURETY CORPORATION,

vs
HEIRS OF VICENTE CORONADO, MAURA CORONADO, SIMEON CORONADO, JULIAN
CORONADO and CRUZ B. CARBON,
G.R. No. 180357

Facts:
Respondents all surnamed Coronado, are the legal heirs of Doroteo Garcia. They filed a
complaint for Annulment of Title and/or Reconveyance against petitioner that Doroteo Garcia
owned a parcel of land located at Antipolo City. After Garcia's death, the respondents
maintained the ownership of the said land, but later discovered that a portion of the land was
registered in the name of a certain Gaudencio T. Bocobo. Respondents prayed that this TCT be
declared null and void.
In its answer, petitioner averred that it issued a performance bond in favor of Gaudencio
T. Bocobo which was secured by a real estate mortgage over the said land. Before it conformed
to the mortgage, it verified and examined Bocobo's title and found it to be free from any
suspicion. When Bocobo failed to pay his obligations, petitioner forclosed the mortgage and
that no other person had claimed interest over the property.
Issue:
i. Whether or not the lower court committed grave abuse of discretion in not dismissing
respondents complaint and disregarding the indefeasibility of the Torrens title.
ii. Whether or not the lower court erred in not ruling that respondents claim was barred
by prescription and laches.
Ruling:
Yes. Initially, we confront the issue of whether the action has prescribed, considering
that several years have already passed since TCT No. N-19781 was issued, and petitioners title
has already become indefeasible and incontrovertible. The contention apparently lacks merit.
The records reveal that the respondents have been in possession of the subject property since
1938. Jurisprudence abounds in holding that, if a person claiming to be the owner is in actual
possession of the property, the right to seek reconveyance, which in effect seeks to quiet title to
the property, does not prescribe.
 SECOND DIVISION
[G.R. No. 140228. November 19, 2004]

FRANCISCO MEDINA et. al, vs. REENFIELD DEVELOPMENT CORPORATION

Facts:
Petitioners are the grandchildren of Pedro Medina from two marriages. On June 5, 1962,
Pedro, his brother Albert and niece Nazaria executed a notarized Contract to Sell in favor of
respondent over a parcel of land. A Deed of Absolute Sale with Mortgage was now executed,
signed by Pedro and company, as vendors. By virtue of these sales, respondent was able to
register in its name the title to the two parcels of land in the name of respondent.
On Nov. 6, 1998, petitioners executed an action for annulment of titles and deeds
reconveyance, damages with preliminary injunction and restraining order, against respondent.
Petitioners allege in their complaint that they are co-owners of these two parcels of land.
petitioners maintain that the deeds of sale on these properties were simulated and fictitious,
and the signatures of the vendors therein were fake. Despite the transfer of the title to
respondent's name, they remained in possession thereof and in fact, their caretaker, a certain
Santos Arevalo and his family still reside on a portion of the property. Respondent constructed a
fence on the property and posted security personnel, barring their ingress and egress.
Respondent denied the allegations, stating that petitioners have no valid claim on the
properties as it is already titled in its name by virtue of the public documents executed by their
predecessors.
Issue:
Whether or not the CA committed a mistake in holding that respondent was in
constructive possession of the subject premises notwtithstanding that petitioners are in actual
possession thereof
Ruling:
Possession and ownership are two different legal concepts. Just as possession is not a
definite proof of ownership, neither is non-possession inconsistent with ownership. Even
assuming that petitioners' allegations are true, it bears no legal consequence in the case at hand
because the execution of the deeds of conveyances is already deemed equivalent to delivery of
the property to respondent, and prior physical delivery or possession is not legally required.
Under Article 1498 of the Civil Code, "when the sale is made through a public instrument, the
execution thereof shall be equivalent to the delivery of the object of the contract, if from the
deed the contrary does not appear or cannot be inferred." Possession is also transferred, along
with ownership thereof, to respondent by virtue of the notarized deeds of conveyances.
In sum, the trial court committed grave abuse of discretion in issuing the writ of preliminary
injunction, and the Court of Appeals was correct in nullifying the same.
 G.R. No. 124699 July 31, 2003
BOGO-MEDELLIN MILLING CO., INC.,
vs.
COURT OF APPEALS AND HEIRS OF MAGDALENO VALDEZ SR.,
Facts:
Magdaleno Valdez, Sr. purchased from Feliciana Santillan, a parcel of unregistered land.
He took possession of said land and declared it for tax purposes in his name. Prior to the sale,
however, the entire length of the land from north to south was already traversed in the middle
by railroad tracks owned by petitioner Bogo-Medellin Milling Co., Inc. The tracks were used for
hauling sugar cane from the fields to petitioners sugar mill. When Valdez Sr. passed away,
private respondents inherited said land. Unknown to them, Bomedco was able to have the
disputed middle lot which was occupied by the railroad tracks placed in its name. When the
respondent learned about this, they immediately demanded the legal basis for Bomedco's
claim, but the letter was unheeded. Bomedcos principal defense was that it was the owner and
possessor of Cadastral Lot No. 954, having allegedly bought the same from Feliciana Santillan in
1929, prior to the sale of the property by the latter to Magdaleno Valdez, Sr. in 1935. It also
contended that plaintiffs claim was already barred by prescription and laches because of
Bomedcos open and continuous possession of the property for more than 50 years.
Issue:
Whether or not the plaintiff's claim was already barred by prescription and latches.
Ruling:
The petitioner cannot find refuge in the principle of laches. It is not just the lapse of time
or delay that constitutes laches. The essence of laches is the failure or neglect, for an
unreasonable and unexplained length of time, to do that which, through due diligence, could or
should have been done earlier, thus giving rise to a presumption that the party entitled to assert
it had either abandoned or declined to assert it. Records show that respondent heirs only
learned about petitioners claim on their property when they discovered the inscription for the
cadastral survey in the records of the Bureau of Lands in 1989. Respondents lost no time in
demanding an explanation for said claim in their letters to the petitioner dated March 1, 1989
and April 6, 1989. When petitioner ignored them, they instituted their complaint before the
Regional Trial Court of Cebu City on June 8, 1989.