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DESAMPARADOS M. SOLIVA v. INTESTATE ESTATE OF MARCELO M. VILLALBA

FACTS:

Desamparados M. Soliva filed a complaint for recovery of ownership, possession, and damages against Valenta Balicua Villalba, alleging that she is the owner of a parcel of agricultural land. Captain Marcelo Villalba, who occupied the house on said land, promised to buy the house and lot upon receipt of his money from Manila and gave her P600.00 for the occupation of the house. Captain Villalba died without having paid the consideration for the house and lot. After his death, Valenta refused to vacate the property, destroyed the house, and constructed a new one. The court ruled in favor of Soliva, but a petition for relief was filed by Valenta. The Court of Appeals reversed the order, stating that the complaint should have been filed against the administrator of the estate of Marcelo Villalba. An amended complaint was subsequently filed, alleging that the house and lot were sold to Marcelo Villalba by Magdaleno Soliva, Desamparados' late husband. The court eventually dismissed the complaint and ordered the reconveyance of the property to Valenta and Valenta's intervention. The Court of Appeals affirmed the decision, stating that laches had already set in. Petitioner raises issues of whether she is barred from recovering the disputed property and whether the court's decision would unjustly enrich the respondents.

ISSUES:

  1. Whether the petitioner's claim is already barred due to prescription and laches.

  2. Whether the oral contract of sale between the parties is invalid due to nonpayment of the full purchase price.

  3. Whether or not the petitioner's claim is barred by laches.

  4. Whether or not the petitioner's claim is barred by prescription.

  5. Whether the petitioner is barred from invoking the 30-year prescriptive period for commencing real action over immovables.

  6. Whether the petitioner is entitled to collect the unpaid balance of the purchase price of the subject property.

RULING:

  1. The Court ruled that the petitioner's claim is barred due to laches. Laches refers to the failure or neglect, for an unreasonable and unexplained length of time, to assert a right. In this case, the petitioner waited for 16 years to assert her claim, which is considered an unreasonable length of time. Therefore, her claim is barred by laches.

  2. The Court ruled that the oral contract of sale between the parties is valid and enforceable. Although a contract of sale of real property must be in a public document, an otherwise unenforceable oral contract may be ratified by the failure to object to the presentation of oral evidence or by the acceptance of benefits under it. In this case, the petitioner accepted payments under the oral contract, which ratified the contract and made it valid and enforceable.

  3. The petitioner's claim is barred by laches. The court held that the petitioner's delay in asserting her right to collect payment or seek rescission of the contract for over 16 years, from 1966 to 1982, constituted laches. The respondent had spent a considerable amount on renovating the property and introducing improvements, and it would be inequitable and unjust to allow the petitioner to assert her claim at this late stage.

  4. The petitioner's claim is also barred by prescription. The court held that the respondent's continuous possession of the property for over 16 years, from 1966 to 1982, constituted ordinary acquisitive prescription. The respondent came into possession through a sale by the petitioner, whom he believed was the owner at that time. All the elements of ordinary acquisitive prescription, including good faith and just title, were present.

  5. The petitioner is barred from invoking the 30-year prescriptive period for commencing real action over immovables.

  6. According to Article 1141 of the Civil Code, real actions over immovables prescribe after thirty years. However, this provision is without prejudice to what is established for the acquisition of ownership and other real rights by prescription. In this case, the respondent has already acquired ownership over the subject property through ordinary acquisitive prescription.

  7. The petitioner is entitled to collect the unpaid balance of the purchase price of the subject property.

  8. Although the petitioner is barred from recovering the subject property, the respondent admitted that a balance of P1,250 of the total purchase price remains unpaid. To allow the respondent to keep the property without paying fully for it would amount to unjust enrichment. Therefore, the petitioner should be allowed to collect this sum.

PRINCIPLES:

  • Laches is the failure to assert a right within a reasonable period, warranting the presumption of abandonment or declination to assert the right.

  • An oral contract of sale of real property may be ratified by the acceptance of benefits under it, making it valid and enforceable.

  • Laches does not concern itself with the character of the defendant's title, but only with the issue of whether or not the plaintiff, due to long inaction or inexcusable neglect, should be barred entirely from asserting the claim. It is concerned with the effect of unreasonable delay.

  • Even a registered owner of property may be barred from recovering possession of property by virtue of laches.

  • Prescription applies to the acquisition of ownership and other real rights over immovables. Possession must be for 10 years, in good faith, and with just title.

  • Good faith consists of the reasonable belief that the person from whom the possessor received the property was its owner and could transmit ownership, while just title is acquired through one of the modes recognized by law for the acquisition of ownership or other real rights.

  • Prescription of real actions over immovables prescribe after thirty years, subject to the acquisition of ownership and other real rights by prescription.

  • No one shall unjustly enrich oneself at the expense of another.

  • Legal interest at six percent (6%) per annum is imposed on the unpaid balance of the purchase price, which will be computed from the time the claim was made judicially until the finality of the judgment. Subsequently, interest of 12 percent per year shall be imposed on that amount upon the finality of the judgment until its payment.