In a dispute over land ownership, the Supreme Court ruled that a claimant’s right to recover property can be barred by extinctive prescription, even if they hold the registered title. This means that if a landowner delays asserting their rights for an extended period, they may lose the ability to reclaim their property, especially if another party has been in possession and exercising ownership rights. This decision underscores the importance of timely action in protecting one’s property interests and prevents landowners from indefinitely delaying legal challenges.

Thirty Years in the Balance: Can a Land Title Be Lost to Time?

The case of Heirs of Angel Yadao vs. Heirs of Juan Caletina revolves around a parcel of land in Cagayan, originally owned by Juan Caletina. After Juan’s death, his heirs allegedly sold the land to the Yadao family in 1962. However, the sale was complicated by issues with the documentation and the status of some of the sellers. For over three decades, the Yadao family occupied and possessed the land. In 1993, the Caletina heirs filed a complaint to reclaim the property, arguing that the sale was invalid and that they were the rightful owners based on the original land title. The central legal question was whether the Caletina heirs’ claim was barred by prescription due to the long period of time that had passed since the alleged sale.

The Regional Trial Court (RTC) initially sided with the Caletina heirs, declaring them the rightful owners. The Court of Appeals (CA) affirmed this decision, emphasizing that prescription does not apply to registered lands. However, the Supreme Court reversed these rulings, focusing on the principle of extinctive prescription. This principle differs from acquisitive prescription, which involves gaining ownership through long-term possession. Extinctive prescription, on the other hand, concerns the loss of a right to bring an action due to the passage of time. As the Supreme Court explained,

“[t]here are two kinds of prescription provided in the Civil Code. One is acquisitive… The other kind is extinctive prescription whereby rights and actions are lost by the lapse of time.”

In essence, even if the Caletina heirs had a valid claim to the land, their prolonged inaction could prevent them from enforcing that claim.

The Court emphasized that while registered land is generally protected from acquisitive prescription, it is not immune to extinctive prescription. The key factor is the length of time that has passed since the cause of action arose. The Court noted that the Caletina heirs were aware of the Yadao family’s possession of the land since 1962, yet they did not file their complaint until 1993 – over 30 years later. This delay, the Court held, was fatal to their claim.

The Court further addressed the issue of the Contrata, the initial agreement of sale, which was not notarized. While a notarized deed carries more weight, the Court clarified that the absence of notarization does not invalidate the transaction itself. The Court stated,

“[t]he provision of Article 1358 of the Civil Code on the necessity of a public document is only for convenience, and not for validity or enforceability.”

The core elements of a valid contract – consent, cause, and consideration – were present, making the Contrata binding between the parties. Additionally, the Court considered the fact that the Yadao family had been in continuous possession of the land and had even received the original certificate of title. The possession of the certificate of title further solidified the Yadao family’s claim.

Ultimately, the Supreme Court’s decision hinged on the application of extinctive prescription. The Court found that the Caletina heirs’ right to reclaim the property had been extinguished by their long delay in asserting their rights. Even though Juan Caletina was described to be married to Casiana Dalo in OCT No. P-479 (S), she could not have validly sold or transferred any right in it to petitioners’ predecessor-in-interest Josefina Yadao. The Court emphasized the importance of vigilance in protecting one’s property rights and warned against sleeping on those rights. As the Court stated, “[t]he law aids only the vigilant, not those who slumber on their rights.” The Court said that by the time the complaint for recovery of Lot 1087 was filed with the RTC, the ultimate and all-encompassing prescriptive period of 31 years had already lapsed. It no longer matters whatever respondents’ cause of action was – contract or constructive trust arising from a mistake or even fraud.

This ruling serves as a reminder that simply holding a title to land is not enough to guarantee ownership. Landowners must actively protect their interests and promptly assert their rights when those rights are challenged. Failure to do so can result in the loss of their property, regardless of the validity of their original claim. The Yadao family was declared co-owners of Lot 1087 of Cadaster 317-D, located at Barangay Taggat Norte, Claveria, Cagayan with a total area of 1,797 square meters and covered by Original Certificate of Title No. P-479 (S).

FAQs

What was the key issue in this case?	The key issue was whether the heirs of Juan Caletina’s claim to recover land from the Yadao family was barred by extinctive prescription due to their prolonged delay in asserting their rights.
What is extinctive prescription?	Extinctive prescription is the principle that the right to bring a legal action expires after a certain period of time, even if the underlying claim is valid. It differs from acquisitive prescription, which involves gaining ownership through long-term possession.
Why did the Supreme Court rule in favor of the Yadao family?	The Supreme Court ruled in favor of the Yadao family because the Caletina heirs waited over 30 years to file their complaint, and their right to reclaim the property was extinguished by extinctive prescription.
Does this mean registered land can be lost through prescription?	While registered land is generally protected from acquisitive prescription, it is still subject to extinctive prescription. This means that a landowner can lose the right to reclaim their property if they delay asserting their rights for an extended period.
What was the significance of the Contrata in this case?	The Contrata, while not notarized, was considered a valid contract of sale because it contained the essential elements of consent, cause, and consideration. The Yadao family also had the original certificate of title.
What is the main takeaway from this ruling?	The main takeaway is that landowners must be vigilant in protecting their property interests and promptly assert their rights when those rights are challenged. Delaying legal action can result in the loss of their property, regardless of the validity of their original claim.
Who was Casiana Dalo?	Casiana Dalo was the common-law wife of Juan Caletina. She signed as the VENDOR of the DEED OF ABSOLUTE SALE.
What steps should landowners take to protect their property rights?	Landowners should regularly monitor their property, promptly address any encroachments or challenges to their ownership, and seek legal advice when necessary to ensure their rights are protected.

The Supreme Court’s decision in this case underscores the importance of diligence and timeliness in protecting property rights. Landowners cannot afford to be passive; they must actively safeguard their interests and take prompt legal action when necessary. Failure to do so may result in the loss of their property, even if they hold the registered title. This case serves as a cautionary tale and a call to action for all landowners to be vigilant and proactive in defending their property rights.

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: Heirs of Angel Yadao, G.R. No. 230784, February 15, 2022