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HEIRS OF TRANQUILINO LABISTE v. HEIRS OF JOSE LABISTE

FACTS:

In 1919, Epifanio Labiste purchased Lot No. 1054 of the Banilad Friar Lands Estate for P36.00. In 1924, the Bureau of Lands Director executed a Deed of Conveyance selling and ceding Lot No. 1054 to Epifanio and his siblings, who were the heirs of Jose Labiste. Prior to the issuance of the deed, Epifanio executed an Affidavit stating that he and Tranquilino Labiste, his uncle and the predecessor-in-interest of the petitioners, co-owned Lot No. 1054. In 1928, Lot No. 1054 was divided into two lots: Lot No. 1054-A for Tranquilino and Lot No. 1054-B for Epifanio. In 1939, the heirs of Tranquilino purchased the one-half interest of the heirs of Jose in Lot No. 1054.

During World War II, the heirs of Tranquilino were forced to flee Cebu City, and upon their return, they discovered that their homes and possessions had been destroyed and squatters had taken over the entire property. In 1993, the respondents filed a petition for reconstitution of title over Lot No. 1054. A compromise agreement was reached, whereby the petitioners would be given time to file a complaint for reconveyance. However, the respondents failed to honor the compromise agreement, prompting the petitioners to file a complaint for annulment of title and reconveyance of the property. The trial court ruled in favor of the petitioners, accepting the presented documents as genuine and authentic.

ISSUES:

RULING:

PRINCIPLES:

  • Prescription is a legal principle which bars the remedy or action to enforce a right after the lapse of a certain period of time. It requires the concurrence of the following elements: (1) the action or right is one which must be brought within a specified period; and (2) the period prescribed has lapsed. Prescription commences to run from the day the right of action accrues.

  • Laches is the failure or neglect for an unreasonable and unexplained length of time, to do that which, through proper and ordinary diligence, could or should have been done earlier. It is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned it or declined to assert it.

  • Ancient documents are those documents more than 30 years old, produced from a custody in which they would naturally and properly be found, and unblemished by any alterations or circumstances of suspicion. They are presumed to be genuine and authentic, and have in their favor the presumption of regularity.