GR 130876; (January, 2002) (Digest)
G.R. No. 130876 . January 31, 2002.
FRANCISCO M. ALONSO, substituted by his heirs, petitioners, vs. CEBU COUNTRY CLUB, INC., respondent.
FACTS
Petitioner Francisco M. Alonso, representing his father Tomas N. Alonso’s estate, claimed ownership over Lot No. 727 based on a 1926 final deed of sale from the government under the Friar Lands Act. This deed, however, was never registered due to lacking technical requirements. In 1992, Alonso discovered that title to the lot had been administratively reconstituted in 1948 under TCT No. RT-1310 in the name of United Service Country Club, Inc., respondent Cebu Country Club’s predecessor. The respondent had possessed the land since at least 1935. Alonso demanded reconveyance and, upon refusal, filed a complaint for declaration of nullity of title and recovery of property.
The Regional Trial Court and the Court of Appeals ruled in favor of Cebu Country Club. The lower courts found that Alonso’s action was barred by prescription and laches, emphasizing the Club’s long, open, continuous, and adverse possession of the property for decades. They upheld the validity of the reconstituted title and noted the failure to register the 1926 deed.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the complaint, thereby upholding the respondent’s title and finding the action barred by prescription and laches.
RULING
The Supreme Court DENIED the petition and AFFIRMED the assailed decision. The Court emphasized that the appeal via certiorari raised only questions of fact, which are beyond the scope of its review. The factual findings of the Court of Appeals, which concluded that the action was indeed barred by prescription and laches, are final and conclusive. The Court held that the respondent’s open, continuous, exclusive, and notorious possession of the disputed lot in the concept of an owner for an extensive period, coupled with the petitioner’s failure to assert his claim for decades, constituted laches. Laches is the failure or neglect for an unreasonable 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. Furthermore, the Court found no compelling reason to disturb the lower courts’ factual determination regarding the validity of the respondent’s reconstituted title. The petition, essentially asking for a re-evaluation of evidence, was unavailing.