In Mariano A. Velez, Sr. v. Rev. Francisco Demetrio, the Supreme Court affirmed the Court of Appeals’ decision, reinforcing the principle that prescription and laches do not apply against registered land under the Torrens system. This ruling protects the rights of registered landowners, ensuring they cannot lose their property due to adverse possession or delay in asserting their rights. The decision underscores the indefeasibility of Torrens titles, providing security and stability for land ownership in the Philippines.

Delayed Claims and Disputed Sales: Who Truly Owns the Land?

This case revolves around a parcel of land originally owned by the spouses Felix Radaza and Estefania Abrogar. Upon their death, the land was inherited by their children and grandchildren. The respondents, descendants of Ramona Radaza-Demetrio and Jose Radaza, Sr., filed a complaint for partition, alleging that Mariano Velez, Sr. had claimed and fenced off the property in 1947, denying them access. The petitioners, heirs of Mariano Velez, Sr., argued that Velez had purchased the shares of several original owners and possessed the land openly and continuously as the owner. The core legal question centers on whether the alleged sales to Mariano Velez, Sr. were valid and whether the respondents’ claim was barred by laches due to their delayed action.

The trial court initially ruled in favor of the petitioners, declaring them the absolute owners. However, the Court of Appeals reversed this decision, ordering the partition of the property, allocating 2/5 to the respondents and 3/5 to the petitioners. The appellate court found that the evidence presented by the petitioners to prove the sales of Ramona Radaza’s and Jose Radaza, Sr.’s shares was insufficient and largely based on hearsay. This discrepancy in factual findings between the lower court and the appellate court highlights the importance of credible evidence in establishing land ownership.

One of the central issues was the alleged sale of Ramona Radaza’s share to Filomeno, who then purportedly sold it to Mariano Velez, Sr. The petitioners relied on the affidavit and testimony of Francisco, who claimed to have witnessed the sale. However, the Court of Appeals found Francisco’s testimony unreliable because his whereabouts during the alleged sale were questionable, undermining the credibility of his account. This illustrates the court’s scrutiny of witness testimonies and the need for verifiable evidence.

Similarly, the alleged sale of Jose Radaza, Sr.’s children’s shares by their mother, Ciriaca, was challenged. The Court of Appeals noted that there was no evidence to show that Ciriaca was authorized by her children to make the sale. Petitioners argued that the documents proving the sale were lost during the war, but this was not sufficiently substantiated. Even Felicito, one of Ciriaca’s sons, testified that he had no knowledge of the sale, further weakening the petitioners’ claim. The burden of proving the validity of the sale rested on the petitioners, and their failure to provide adequate evidence led to the rejection of their argument.

The testimony of Isabelo Tabian, a former tenant, was also presented to support the alleged sale. Tabian stated that Ciriaca told him she was selling the land to Mariano Velez, Sr. However, the Court of Appeals deemed this testimony as hearsay, rendering it inadmissible as proof of the sale. Hearsay evidence, which is a statement made out of court that is offered in court as evidence to prove the truth of the matter asserted, is generally not admissible due to its unreliability. The court’s rejection of Tabian’s testimony underscores the importance of direct and credible evidence in establishing legal claims.

The petitioners also argued that the respondents were guilty of laches, having failed to assert their rights over the property for an unreasonable amount of time. The Supreme Court defined laches as:

the failure of or neglect for an unreasonable and unexplained length of time to do that which by exercising due diligence, could or should have been done earlier, or to assert a right within reasonable time, warranting a presumption that the party entitled thereto has either abandoned it or declined to assert it. (Philgreen Trading Construction Corporation v. Court of Appeals, 271 SCRA 719 1997)

However, the Court of Appeals held that laches did not apply because the act of repudiation of the co-ownership occurred only when the petitioners registered an affidavit of adverse claim in 1974. This registration served as a clear notice to the respondents that their ownership was being challenged. Since the case was filed shortly thereafter, the respondents could not be deemed to have slept on their rights.

The Supreme Court agreed with the Court of Appeals, emphasizing that the land was registered under the Torrens system in the names of the respondents and their predecessors in interest. The fact that only 3/5 of the land was allegedly sold to Mariano Velez, Sr. meant that the remaining 2/5 remained in the name of the respondents. The Court highlighted Article 494 of the Civil Code, which states that prescription does not run against a co-owner as long as the co-ownership is expressly or impliedly recognized. The petitioners’ failure to transfer the title of the entire land in their name further supported the recognition of the respondents’ co-ownership.

Furthermore, the Supreme Court underscored that laches cannot prevail against specific provisions of law. The Court cited the Property Registration Decree, which provides that no title to registered land can be acquired by prescription or adverse possession. This principle is crucial in maintaining the integrity and reliability of the Torrens system, which aims to provide security of land ownership.

Under the Property Registration Decree, no title to registered land in derogation to that of the registered owner shall be acquired by prescription or adverse possession. (Section 47, PD 1529)

The Court reiterated the well-settled rule that prescription and laches do not apply to registered land covered by the Torrens system, providing registered owners with the assurance that their ownership is protected. This principle reinforces the security and stability of land titles in the Philippines.

FAQs

What was the key issue in this case?	The key issue was whether the alleged sales of land shares to Mariano Velez, Sr. were valid and whether the respondents’ claim was barred by laches due to their delayed action.
What is laches?	Laches is the failure or neglect to assert a right within a reasonable time, warranting a presumption that the party entitled to it has abandoned or declined to assert it.
Why did the Court rule that laches did not apply in this case?	The Court ruled that laches did not apply because the act of repudiation of the co-ownership occurred only when the petitioners registered an affidavit of adverse claim in 1974, and the respondents filed the case shortly thereafter.
What is the significance of the Torrens system in this case?	The Torrens system provides security of land ownership, and under this system, no title to registered land can be acquired by prescription or adverse possession.
What is hearsay evidence, and why was it rejected in this case?	Hearsay evidence is a statement made out of court that is offered in court as evidence to prove the truth of the matter asserted; it was rejected due to its unreliability.
What is the effect of Article 494 of the Civil Code on this case?	Article 494 of the Civil Code states that prescription does not run against a co-owner as long as the co-ownership is expressly or impliedly recognized, which supported the respondents’ claim.
What did the Court of Appeals decide?	The Court of Appeals reversed the trial court’s decision and ordered the partition of the property, allocating 2/5 to the respondents and 3/5 to the petitioners.
What was the Supreme Court’s ruling?	The Supreme Court affirmed the Court of Appeals’ decision, reinforcing the principle that prescription and laches do not apply against registered land under the Torrens system.

The Supreme Court’s decision in this case reaffirms the importance of the Torrens system in safeguarding land ownership rights in the Philippines. It underscores that registered owners can rely on their titles without fear of losing their property due to prescription or laches. This ruling promotes stability and certainty in land transactions and provides assurance to landowners.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Mariano A. Velez, Sr. v. Rev. Francisco Demetrio, G.R. No. 128576, August 13, 2002