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TIRO v. SPS. LEON V. CASALS

FACTS:

The case involves a disputed 5,354-square meter parcel of land in the former municipality of Opon, Province of Cebu. The claimants are the descendants of Mamerto Ingjug, who allege that they have been deprived of their successional rights through fraud and misrepresentation. The respondents, on the other hand, are a group of vendees who claim to have acquired the property for value and in good faith.

The descendants of Mamerto Ingjug filed a complaint seeking partition, recovery of ownership and possession, and nullification of the sale of the property. However, the trial court dismissed the complaint on the ground of prescription and laches. This decision was affirmed by the Court of Appeals.

The petitioners now seek a review of the appellate court's decision, arguing that the property, being originally registered under the Torrens system, cannot be acquired through prescription or adverse possession. They also assert that laches cannot be a valid defense for claiming ownership of land registered under the Torrens system.

ISSUES:

  1. Whether the right to institute a complaint for partition and reconveyance is barred by prescription and laches.

  2. Whether the contract is null and void ab initio due to the death of one of the parties.

  3. Whether the claims of prescription and laches can be invoked in this case.

RULING:

  1. The Supreme Court granted the petition, stating that the trial court and the Court of Appeals dismissed the complaint based on prescription and laches without considering the other issues raised by the petitioners. The court emphasized that the action filed by the petitioners was not only for reconveyance based on a constructive trust resulting from fraud but also for partition, recovery of ownership and possession, and declaration of nullity of certain deeds. The court ruled that the nullity of the deeds of sale and the extrajudicial settlement and confirmation of the sale is the basic premise of the civil action. The court also held that the sale of the property to the respondents is null and void as it prejudiced the interests of the petitioners. Therefore, the claim that the right to institute the complaint is barred by prescription and laches is not valid.

  2. The contract is null and void ab initio due to the death of one of the parties. The death of a person terminates contractual capacity.

  3. The claim of prescription of action and laches cannot be invoked in the case. The action for the declaration of the inexistence of a contract does not prescribe, and laches cannot be set up to resist the enforcement of an imprescriptible legal right.

PRINCIPLES:

  • The right to recover possession of a registered property is imprescriptible.

  • Laches is not a valid defense for claiming ownership of land registered under the Torrens system.

  • Possession cannot be characterized as adverse possession in good faith if the possessor is holding the land in trust for the true owners.

  • Prescription would not apply when the property ownership is acquired through fraud or mistake.

  • Contracts that are null and void ab initio have no legal effects.

  • A contract is null and void if one of the parties is already dead at the time of its execution.

  • The action for the declaration of the inexistence of a contract does not prescribe.

  • Laches cannot be invoked to resist the enforcement of an imprescriptible legal right.