28/05/2026
“A 50-YEAR-OLD DEED OF SALE VERSUS A CERTIFICATE OF TITLE”
FRANCISCA SUMAMPONG vs. HEIRS OF BENIGNA SUMAMPONG-SARATE
G.R. No. 277682, February 5, 2026
FACTS:
The dispute involves a 17,094-square-meter parcel of land located in Loboc, Bohol, covered by Original Certificate of Title (OCT) No. 27731 in the name of the late Benigna Sumampong.
Benigna’s grandchildren (Heirs of Benigna) discovered via a lot resurvey in August 2012 that the petitioner, Francisca Sumampong, was occupying a substantial 3,000-square-meter portion of the land.
The Heirs of Benigna demanded that Francisca vacate. When she refused, they filed a complaint for recovery of possession and quieting of title. Francisca countered that she purchased the portion from Ruperto Dante in 1966 via a notarized Deed of Absolute Sale, built a house on it in 1973, and held a tax declaration in her name.
The Regional Trial Court (RTC) ruled in favor of Francisca, finding the heirs barred by laches. However, the Court of Appeals (CA) reversed the RTC, declaring the heirs the rightful owners because an OCT prevails over a tax declaration and laches did not apply.
ISSUE/S:
Who holds the better right of possession over the disputed property—Francisca (the buyer with an unregistered deed/tax declaration) or the Heirs of Benigna (the heirs of the registered owner under the Torrens System)?
Are the Heirs of Benigna barred by the principle of laches?
RULING:
The Heirs of Benigna hold the better right of possession. A Torrens certificate of title is evidence of an indefeasible title, and its holder is strictly entitled to possession. Francisca's unregistered Deed of Absolute Sale and real property tax receipts cannot prevail over the registered OCT.
No, the heirs are not barred by laches. The action to recover possession of registered land does not prescribe. Furthermore, the heirs acted diligently and without undue delay upon discovering the exact encroachment in 2012. The Supreme Court denied Francisca's petition and affirmed the CA decision.
ACCORDINGLY, the Petition for Review on Certiorari is DENIED. The March 22, 2024 Decision and the September 17, 2024 Resolution of the Court of Appeals in CA-G.R. CV No. 07850 are AFFIRMED.
Doctrine: A certificate of title serves as evidence of an indefeasible and incontrovertible title to the property. As against a registered owner (or their legal heirs in cases of death of the registered owner) and the holder of an unregistered deed of sale or tax declaration, the registered title holder always maintains a superior and better right to possess the land.
An action to recover possession of registered land under the Torrens System does not prescribe. This imprescriptibility extends fully from the registered owner to their heirs.
