Catholic Bishop of Balanga v. Court of Appeals
G.R. No. 112519 (November 14, 1996)
Facts:
The case involves a dispute over a parcel of land (Lot No. 1272) located in Puerto Rivas, Balanga, Bataan, originally owned by the Roman Catholic Archbishop of Manila. The ownership was later transferred to the Roman Catholic Bishop of San Fernando, Pampanga, and subsequently to the Catholic Bishop of Balanga, which was registered as a corporation in December 1975.
On August 23, 1936, Rev. Fr. Mariano Sarili, the parish priest, executed a deed of donation (Escritura De Donacion) donating a portion of Lot No. 1272, measuring 265.36 square meters, to Ana de los Reyes as a reward for her long service to the church. Although Ana accepted the donation, the deed was never registered with the Register of Deeds for unknown reasons. Ana de los Reyes passed away in 1939 without any heirs, but she had given the property to her nephew, Amando de Leon (the private respondent), who took possession of the property, built a house, and paid taxes on it.
The petitioner, Catholic Bishop of Balanga, filed a complaint against De Leon on November 5, 1985, claiming that he had occupied the property without consent since the Japanese occupation and refused to vacate despite requests. De Leon argued that he was the lawful owner due to the donation and that the complaint was filed to harass him.
The Regional Trial Court ruled in favor of the petitioner, stating that the donation was invalid due to the lack of authority from the Archbishop and the failure to secure prior court approval for the donation. De Leon appealed to the Court of Appeals, which reversed the RTC's decision, citing the doctrine of laches due to the petitioner's inaction for 49 years.
Legal Issues:
- Whether the private respondent could prevail over the registered owner despite the latter's indefeasible title under the Torrens system.
- Whether the defense of laches could be applied to bar the petitioner's claim for recovery of possession.
Arguments:
Petitioner (Catholic Bishop of Balanga):
- Argued that the donation was invalid as Rev. Fr. Sarili lacked the authority to execute it and that the deed was unenforceable under Article 1403 of the New Civil Code.
- Contended that the Court of Appeals erred in applying the doctrine of laches since the private respondent did not assign it as an error on appeal.
Respondent (Amando de Leon):
- Maintained that he was the lawful owner of the property through the donation and that the complaint was filed too late, constituting harassment.
- Asserted that the defense of laches should apply due to the petitioner's long inaction, which prejudiced his rights.
Court's Decision and Legal Reasoning:
The Court of Appeals ruled in favor of De Leon, applying the doctrine of laches. It found that the petitioner had been aware of De Leon's possession since the donation in 1936 but failed to act for 49 years. The court emphasized that while a Torrens title is indefeasible, a registered landowner can lose the right to recover possession due to laches.
The court outlined the elements of laches: (1) conduct by the defendant leading to the situation complained of; (2) delay in asserting the right after knowledge and opportunity to sue; (3) lack of notice to the defendant of the complainant's intention to assert the right; and (4) injury or prejudice to the defendant if relief is granted. All elements were present in this case, leading to the conclusion that the petitioner’s inaction for an unreasonable length of time barred its claim.
The Supreme Court upheld the Court of Appeals' decision, affirming that the petitioner could not claim nullity of the donation as an excuse for its inaction. The ruling reinforced the principle that laches can operate as a bar to claims, even against registered landowners.
Significant Legal Principles Established:
- The doctrine of laches can bar a claim for recovery of possession of registered land, despite the indefeasibility of a Torrens title.
- A registered landowner may lose the right to recover possession due to inaction and neglect over an unreasonable period, leading to prejudice against the possessor.
- The elements of laches include the defendant's conduct, the complainant's delay, lack of notice to the defendant, and potential injury to the defendant.