Principle of laches


The principle of laches is creation of equity. It is applied, not really to penalize neglect or sleeping upon one's right, but rather to avoid recognizing a right when to do so would result in a clearly inequitable situation (Asuncion v. CA Et. Al., 150 SCRA 353 [1987]).

Petitioners' action is inevitably barred by the equitable principle of laches. Petitioners were aware that the land was in the actual possession of private respondent and his predecessor-in-interest but did nothing to immediately claim it or verify the status of their possession. As observed by this Court under similar circumstances, there is evidently a failure or neglect for an unreasonable and unexplained period of time to do what they claimed they were entitled to do, where petitioners failed to institute any action for reconveyance nor did they seek reconveyance until about twenty five (25) years from the execution of the Deed of Sale. Such negligence or failure warrants the assumption that the parties claiming to be entitled to assert it, either had abandoned it, or had decided that they were not entitled to assert it and thus, acquiesced in it.

As correctly appreciated by the Court of Appeals, the defenses of prescription and laches lie. Both the legal defense of prescription and the equitable defense of laches clearly lie against the plaintiffs' right, if any, to recover the ownership and possession of the land. They admit that the land was sold by Ignacio Arradaza to Estelita M. Bangloy on October 21, 1947. The time-honored rule anchored on public policy is that relief will be denied to a litigant whose claim or demand has become "stale" or who has acquiesced for an unreasonable length of time, or who has not been vigilant or who has slept on his rights either by negligence, folly or inattention.
It is strange why it took appellants twenty-seven (27) years (October 21, 1947 to January 18, 1975) within which to definitely pursue a legal action to enforce their alleged claim. This delay and indifference, which have not been satisfactorily explained by them militate against the validity of the alleged right that they are seeking to enforce in the case at bar. The assertion of a doubtful claim after a long delay cannot be forwarded by the courts. On the issue of prescription, this Court has invariably ruled in numerous decisions that an action for recovery of title, or possession of, real property or an interest therein can only be brought within ten (10) years after the cause of action accrues. In the instant case, the cause of action for reconveyance must be deemed to have occurred on October 21, 1947 when the deed of sale in favor of Estelita M. Bangloy who immediately took possession of the land was executed. (Arradaza, et al. v. CA & Larrazabal. G.R. No. 50422. February 8, 1989)

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