Scribd
Upload
121 views2 pages

Aledro-Runa v. LEADC - Possession & Laches

This case involves a dispute over possession of two parcels of land originally registered under Segundo Alendro. The Supreme Court ruled that: 1) The petitioner, as heir to the registered owner, had a better right to possess the properties. A prior court decision declaring null and void an absolute deed of sale executed by Segundo had attained finality. 2) The petitioner's action to recover possession did not prescribe. Under the Land Registration Act, no title to registered land can be acquired through prescription or adverse possession against the registered owner. 3) Neither laches nor prescription can prevent the petitioner, as heir to the registered owner, from recovering possession of registered properties under the Torrens System.

Uploaded by

Aaron Ariston
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
121 views2 pages

Aledro-Runa v. LEADC - Possession & Laches

This case involves a dispute over possession of two parcels of land originally registered under Segundo Alendro. The Supreme Court ruled that: 1) The petitioner, as heir to the registered owner, had a better right to possess the properties. A prior court decision declaring null and void an absolute deed of sale executed by Segundo had attained finality. 2) The petitioner's action to recover possession did not prescribe. Under the Land Registration Act, no title to registered land can be acquired through prescription or adverse possession against the registered owner. 3) Neither laches nor prescription can prevent the petitioner, as heir to the registered owner, from recovering possession of registered properties under the Torrens System.

Uploaded by

Aaron Ariston
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

Aledro-Runa v.

Lead Export and Agro-Development Corporation


GR No. 225896
July 23, 2018

GEMUNDO,J.:

NATURE OF THE ACTION:


This is a civil case for the determination of better right of possession

FACTS:
This case originated from 3 different civil cases involving 2 parcels of land
– Lots 3014 & 5722, covered by OCT P-1781 & P-1712. The 2 parcels of land
were registered in the name of Segundo Alendro (Segundo). Allegedly,
Segundo executed 2 contracts covering the parcels of land.

1. Contract of lease – Between Segundo and Alfredo Rivera (Rivera) 1972


2. Deed of absolute sale – Segundo and Mario Advento (Advento) 1981

1982 – Aventosold the properties to Andres Ringor (Ringor)

1988 – Farmingtown Agro-Developers, Inc. (FADI) leased the 2 parcels of land


from Ringor for a period of 25 years.

1st Civ Case: Civil Case No. 95-13


- Heirs of Segundo filed a complaint against FADI and Advento Before RTC Br.
34 for the declaration of nullity of deed and damages.
- RTC dismissed the complaint, hence heirs of Segundo appealed to CA.
- FADI in the mean time merge with respondent, then named as Lead Export
Corporation, which is now Lead Export and Agro-Development
Corporation (LEADC). LEADC absorbed FADI’s occupation and possessory
rights pertaining to the 2 parcels of land.
- CA reversed the decision RTC, remanded case for further evidence
- Atty. Nilo Aledro (Nilo) filed a motion to dismiss with prejudice on the ground
of lack of interest to prosecute the case and to protect Advento and FADI
from further prosecution; granted by RTC Br. 34

2nd Civ Case: Civil Case No, 41-2005


- (Sofia), widow of Segundo filed before RTC Br.4 for delaration of Nullityo f
Deed of sale and Quieting of title alleging that through fraud, she and
Segundo were made to believe that htey were signing a contract of lease and
not a deed of absolute sale.
- Summons were issued to Advento, but he did not appear despite publication
being resored to.
- RTC Br. 4 declared Advento in default, and ruled in favor of Sofia with an
issued certificate of finality of decision.

Present Casel Civil Case No 218-10


- Carmen Aledro-Runa (Aledro-Runa) filed a case for unlawful detainer,
damages and atty’s fees against respondent before MCTC.
- LEADC alleged that it had a right of possession over the properties based on
the contract of lease between Ringor and FADI; possessory rights were
based on the deeds of absolute sale between Segundo and Advento, and
later between Advento and Ringor
- LEADC argued that case should be dismissed based on res judicata as the
previous complaint has already been dismissed with prejudice
Meanwhile Ringor sold the properties to (Gonzles & Cabunas) who then
entered into a contract of lease with Lapanday Foods Corporation (Lapanday).

RTC Br. 4 reversed the decision of the MCTC for lack of jurisdiction.
During trial RTC Br. 4 dismissed the case for lack of merit as it was barred by re
judicata and thus held the validity of the deeds of sale covering the series of
transaction involving subject property. CA denied the appeal and affirmed in toto
the decision of the RTC Br. 4.

ISSUE:
1. Whether or not the CA erred when it did not rule that Aledro-Runa had
better right to possess the subject parcels of land
2. Whether or not he CA erred when it ruled that Aledro-Runa’s action
had already prescribed.

HELD:
1. No. an action for declaration of nullity of deed of sale and quieting
of titles where the trial court declared the deed of absolute sale executed by
Segundo in favor of Advento as null and void, and ordered the removal of cloud
upon OCT Nos. P-1781 and P-1712, had long attained finality. Said decision was
annotated at the back of the certificates of title. Hence, even assuming arguendo
that the argument of prescription may be correct, the same becomes immaterial
because by virtue of the final and executory decision in Civil Case No. 41-2005,
the only issue left for resolution is who, between the petitioner - the heir of the
registered owner - and the respondent lessee, has a better right to possess the
subject properties.

Respondent's possession as a lessee was based on a contract of lease


executed in its favor by the alleged subsequent buyers of the subject properties,
namely Ringor and later, by Gonzales and Cabuñas. These buyers only had
unregistered deeds of sale in their favor. It is baffling why these deeds, despite
the long span of time, were never registered

Clearly, Ringor, Gonzales and Cabuñas cannot be considered buyers in


good faith because of their failure to exercise due diligence as regards their
respective sale transactions. While this Court protects the right of the innocent
purchaser for value and does not require him to look beyond the certificate of
title, this protection is not extended to a purchaser who is not dealing with the
registered owner of the land. In case the buyer does not deal with the registered
owner of the real property, the law requires that a higher degree of prudence be
exercised by the purchaser

2. Yes, CA erred. An action to recover possession of a registered land


never prescribes in view of the provision of Sec. 44 of Act No. 496 to the effect
that no title to registered land in derogation of that of a registered owner shall be
acquired by prescription or adverse possession. It follows that an action by the
registered owner to recover a real property registered under the Torrens System
does not prescribe. The rule on imprescriptibly of registered lands not only
applies to the registered owner but extends to the heirs of the registered owner
as well. Therefore, petitioner's right to recover possession did not prescribe.
Likewise, laches did not bar petitioner's right of recovery. An action to recover
registered land covered by the Torrens System may not generally be barred by
laches. Neither can laches be set up to resist the enforcement of an
imprescriptible legal right. It is a principle based on equity and may not prevail
against a specific provision of law, because equity, which has been defined as
"justice outside legality," is applied in the absence of and not against statutory
law or rules of procedure.

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy