G.R. No. 106060 June 21, 1999
EMILIE T. SUMBAD and BEATRICE B. TAIT, petitioners, vs. THE COURT OF APPEALS, EDUARD OKOREN, et al., respondents.

FACTS

Petitioners Emilie T. Sumbad and Beatrice B. Tait, children of the spouses George K. Tait, Sr. and Agata B. Tait, filed an action for quieting of title, annulment of sale, and recovery of possession. They claimed that after their mother Agata died in 1936, their father George used the proceeds from the sale of a conjugal property to purchase a lot in Sum-at, Bontoc. George later lived with Maria F. Tait and executed a deed of donation over the Sum-at property in her favor in 1974. After George’s death in 1977, Maria sold portions of the land to private respondents from 1982 to 1983. Petitioners alleged they only discovered these sales in 1988 and that the respondents were warned prior to purchase that the property belonged to George’s heirs.
During pre-trial, petitioners admitted the existence of the deed of donation from George to Maria. The private respondents, as buyers, asserted they were purchasers in good faith, relying on the tax declaration in Maria’s name. They argued the action was barred by laches, noting petitioners’ long inaction despite the sales and their own subsequent possession and introduction of improvements on the lots.

ISSUE

The primary issue is whether the petitioners’ action to annul the sales and recover the property is barred by laches.

RULING

Yes, the action is barred by laches. The Court affirmed the dismissal of the complaint. Laches is the failure 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, warranting a presumption that the party entitled to assert it has abandoned or declined to assert it.
The legal logic is clear from the chronology. Maria Tait sold the lots to respondents between 1982 and 1983. Petitioners, however, filed their complaint only in July 1989, approximately six to seven years later. The Court found this delay unreasonable. Petitioners resided in the same locality and could have discovered the sales earlier through the exercise of ordinary diligence. Their prolonged inaction allowed the respondents, who were purchasers in good faith relying on Maria’s tax declaration, to believe the transactions were secure and to introduce permanent improvements on the land. This change in the respondents’ position, induced by petitioners’ neglect, makes it inequitable to now enforce petitioners’ claim. The defense of laches applies independently of prescription and is grounded on public policy which discourages stale claims. Thus, regardless of the underlying validity of the donation or the sales, petitioners’ failure to assert their rights within a reasonable time precludes them from seeking equitable relief.