Esmaquel v. Coprada

G.R. No. 152423 (December 15, 2010)

Facts:

On February 24, 1997, petitioners Marcos R. Esmaquel and Victoria Sordevilla filed an ejectment case against respondent Maria V. Coprada before the 2nd Municipal Circuit Trial Court (MCTC) of Magdalena, Liliw, and Majayjay, Laguna. The petitioners claimed ownership of a parcel of land located in Barangay San Miguel, Majayjay, Laguna, covered by Transfer Certificate of Title (TCT) No. T-93542. In 1945, the petitioners allowed the respondent and her family to occupy the land under the condition that they would vacate it if the petitioners needed to use it. The respondent constructed a residential house on the property and occupied it rent-free, with the petitioners never demanding her to leave out of pity for her circumstances.

Over the years, the respondent's situation improved, and she acquired her own house elsewhere. The petitioners verbally requested her to vacate the premises, but she refused. Consequently, the petitioners sent a formal demand letter on August 22, 1996, giving the respondent until November 30, 1996, to vacate. When the respondent ignored this demand, the petitioners sought assistance from the barangay authorities, but no settlement was reached, leading to the filing of the ejectment case.

The respondent admitted the petitioners were the registered owners but claimed that her late husband was granted permission by Emiliana Coprada (the original owner and mother of petitioner Victoria) to occupy the land as a permanent residence. She alleged that an oral sale occurred in the early 1960s, where she paid P2,000 for the property, although no written agreement was made. The respondent also claimed to have been paying realty taxes on the property since the alleged sale.

The MCTC dismissed the ejectment case, ruling that laches had set in, preventing the petitioners from questioning the validity of the purported sale. The Regional Trial Court (RTC) later reversed this decision, stating that the respondent's possession was unlawful after the petitioners demanded she vacate the property. The RTC found that the respondent failed to prove the alleged oral sale and ordered her to vacate the premises.

The respondent appealed to the Court of Appeals (CA), which reversed the RTC's decision and reinstated the MCTC's ruling. The petitioners then filed a petition for review with the Supreme Court.

Legal Issues:

1. Whether the petitioners, as registered owners, have a valid ground to evict the respondent from the subject property.
2. Whether the respondent's claim of ownership through an unproven oral sale can defeat the petitioners' right to recover possession.
3. Whether laches applies to the petitioners' claim for recovery of possession.
4. Whether the respondent's possession can be considered lawful despite the petitioners' ownership.

Arguments:

Petitioners' Arguments:

• The petitioners argued that their right to recover possession of the property is never barred by laches, as they are the registered owners under TCT No. T-93542.
• They contended that the respondent's claim of ownership through an oral sale is unproven and that her possession became unlawful upon their demand for her to vacate.
• The petitioners maintained that the respondent's payment of realty taxes does not confer ownership, as the taxes were paid in their name.

Respondent's Arguments:

• The respondent claimed that the property was sold to her in 1962, and thus she has the right to possess it.
• She argued that her long-term possession and payment of taxes should be recognized, and that she is a builder in good faith entitled to reimbursement for improvements made on the property.
• The respondent asserted that the petitioners' claim is barred by laches due to their long inaction in asserting their rights.

Court's Decision and Legal Reasoning:

The Supreme Court granted the petition, reversing the CA's decision and reinstating the RTC's ruling. The Court held that the petitioners, as registered owners, have an indefeasible right to recover possession of their property, which is not barred by laches. The Court emphasized that the respondent's claim of ownership through an unproven oral sale does not defeat the petitioners' right to possession, as the Torrens title serves as conclusive evidence of ownership.

The Court clarified that the issue of ownership raised in an unlawful detainer case is merely provisional and does not bar subsequent actions regarding title. It ruled that the respondent's possession was by mere tolerance, and upon the petitioners' demand for her to vacate, her possession became unlawful.

The Court also addressed the issue of laches, stating that the petitioners' inaction did not constitute a failure to assert their rights within a reasonable time, as they had allowed the respondent to occupy the property with the understanding that she would vacate upon demand. The Court concluded that the respondent's claim of being a builder in good faith was unfounded, as her possession was not based on ownership but on tolerance.

Significant Legal Principles Established:

• The right of a registered owner to recover possession of property is imprescriptible and cannot be barred by laches.
• An unproven oral sale does not defeat the right of a registered owner to possess their property.
• Possession by mere tolerance can be terminated upon demand, leading to unlawful detainer proceedings.
• The validity of a Torrens title cannot be collaterally attacked in an ejectment case.