Case Digest: TEODORO STA. ANA v. LOURDES PANLASIGUE, et al.

TEODORO STA. ANA v. LOURDES PANLASIGUE, et al.

500 SCRA 476 (2006)

The doctrine of laches should never be applied earlier than the expiration of time limited for the commencement of actions, unless, as a general rule, inexcusable delay in asserting a right and acquiescence in existing conditions are proven.

Two parcels of land situated in Pasig City were registered in the name of Petronilo Sta. Ana who died leaving behind his widow Anatolia and ten children. After sometime, Nicolas, one of the ten children of the Sta. Ana couple, died leaving behind two children, Annaliza and Andrea.

In 1988, Anatolia, together with eight of her living children and Fe Sta Ana, the wife of her eldest child-herein petitioner Teodoro Sta. Ana, who was then abroad, executed a Deed of Sale covering the first of the aforementioned lots in favor of herein respondents Lourdes Panlasigue and Julieta P. Santiago. On even date, Anatolia, together with the same eight children and Teodoro‘s wife Fe, donated the second lot to Ireneo Sta. Ana, one of the Sta. Ana children, via a ―Deed of Extrajudicial Partition and Donation.‖

Teodoro, upon coming home to the country in 1996, filed a complaint alleging among others that he did not participate in the extrajudicial partition and donations relative to the conveyance of land in favor of Lourdes, Julieta and Ireneo. He prayed that his share be reconveyed back to him.

The Regional Trial Court of Pasig held that the sale and donations were null and void. On appeal, the Court of Appeals reversed the lower court‘s decision holding that the sale and donations were not null and void. The CA also held that the right of Teodoro to question the title of Lourdes and Julieta has been barred by laches.

ISSUES:

Whether or not Teodoro‘s right to question the title of Lourdes, Julieta and Ireneo has been barred by laches

HELD:

Jurisprudence of course dictates that the “[t]he doctrine of laches should never be applied earlier than the expiration of time limited for the commencement of actions, unless, as a general rule, inexcusable delay in asserting a right and acquiescence in existing conditions are proven.”

From the annotation on May 6, 1988 of the challenged documents on Petronilo’s title up to the filing by Teodoro on August 20, 1996 of the complaint subject of the present case, a period of more than 8 years had elapsed. Gratuitously assuming that the action for reconveyance is based on implied trust, it prescribes in 10 years. Therefore, Teodoro’s complaint had not prescribed when he filed his complaint. The facts and circumstances attendant to the case indicate, however, that there was inexcusable delay on the part of Teodoro in asserting his right and acquiescence in existing conditions.