CASE DIGEST: Mateo v. Diaz (G.R. No. 137305. January 17, 2002)

Below is Paras (2008)'s case brief (case digest) of Quirino Mateo & Matias Mateo v. Dorotea Diaz, et al. (G.R. No. 137305. January 17, 2002) on Page 6 of his books (citations below). The original text of the decision was written under the ponencia of Justice Pardo.

QUIRINO MATEO and MATIAS MATEO, petitioners, vs. DOROTEA DIAZ; REYNALDO DIAZ; REMEDIOS DIAZ; ADORACION DIAZ; NORBERTO DIAZ; YOLANDA CRUZ; OSCAR CRUZ; ESTER CRUZ; NENITA CRUZ; PRIMO POLICARPIO; GAVINO POLICARPIO; FLORENTINA POLICARPIO; MAURO POLICARPIO; and MIGUEL POLICARPIO, respondents.

FACTS: The land involved is registered under the Torrens system in the name of petitioners’ father Claro Mateo. There is no question raised with respect to the validity of the title. Immediately after petitioners discovered the existence of OCT 206 in 1977 or 1978, they took steps to assert their rights thereto. They divided the land between the two of them in an extrajudicial partition. Then petitioners fi led the case below to recover ownership and possession as the only surviving children of original owners, the late Claro Mateo.

The Regional Trial Court (RTC), Bulacan, at Malolos, ruled that prescription and laches are applicable against petitioners, that real actions over an immovable prescribe after 30 years, that ownership can be acquired thru possession in good faith and with just title for a period of 10 years, and that ownership may be acquired thru uninterrupted adverse possession for 30 years without need of just title or of good faith. The Court of Appeals (CA) affi rmed that of the trial court, thus, this petition for review on certiorari.

ISSUE: Can the equitable doctrine of laches may override a provision of the Land Registration Act on imprescriptibility of title to registered land? In other words, is prescription and the equitable principle of laches are applicable in derogation of the title of the registered owner?
HELD: A party who had filed immediately a case as soon as he discovered that the land in question was covered by a transfer certificate in the name of another person is NOT guilty of laches.

An action to recover possession of a registered land never prescribe in view of the provision of Sec. 44 of Act 496 (now Sec. 47 of PD 1529) to the effect that no title to registered land in derogation to that of a registered owner shall be acquired by prescription or adverse possession.

In fact, there is a host of jurisprudence holding that prescription and laches could not apply to registered land covered by the Torrens system. With more reason are these principles applicable to laches, which is an equitable principle. Laches may not prevail against a specific provision of law, since equity, which has been defined as JUSTICE OUTSIDE LEGALITY, is applied in the obscene of and not against statutory law or rules of procedure.

Upon the other hand, the heirs of the registered owner are not estopped from claiming their father’s property, since they merely stepped into the shoes of the previous owners. Prescription is unavailing not only against the registered owner, but also against his hereditary successors because the latter merely step into the shoes of the decedent by operation of law and are merely the continuation of the personality of their predecessorin-interest.

The CA erred in ordering the Register of Deeds to cancel OCT 206 of Claro Mateo and issue new titles to those who are occupying the subject land. This violates the indefeasibility of a Torrens title. The title of Claro Mateo could be cancelled only if there is competent proof that he had transferred his rights over the parcel of land to another party, otherwise title would pass to his heirs only by testate or intestate succession. The fallo: The Supreme Court thereupon reverses the CA’s decision. In lieu thereof, the Court remands the case to the trial court for determination of the heirs of Claro Mateo in a proper proceeding.

The discussion above is based on an outline by Paras (2008) in the first volume of his commentaries on the New Civil Code of the Philippines. His books are available in fine bookstores nationwide. SOURCE: Justice Edgardo Paras (2008). Civil Code of the Philippines Annotated. Volume I on Persons and Family Relations. Rex Book Store. 978-971-23-7989-5. https://www.rexestore.com/cloth-bound/1582-civil-code-of-the-phils-annotated-vol-i-clothbound-.html