Respondents (the Guevara) filed an action for the nullification of the certificates of title of a parcel of land measuring approximately 2,304 hectares situated in Marikina. The Guevara heirs alleged in the complaint that they were the co-owners of a property and the petitioner illegally claimed ownership and possession over a certain portion of the property, Petitioner Pineda filed an answer with counterclaim, raising the defenses of lack of cause of action, prescription, laches and estoppel. He averred that he was a buyer in good faith and had been in actual possession of the land since 1970 initially as a lessor and subsequently as an owner. He registered the property in his name.
The RTC set the case for hearing as if a motion to dismiss had been filed. During the hearing, the parties presented oral arguments and were directed to file their memoranda. The RTC issued an Order, dismissing the action on the ground of laches. The Guevara heirs appealed the order of dismissal, claiming the denial of their right to due process.
The Court of Appeals promulgated the assailed Decision, which set aside the RTC’s order of dismissal and directed the reinstatement of Civil Case. The appellate court ruled that a complaint cannot be dismissed under Rule 16, Section 1 of the Rules of Court based on laches since laches is not one of the grounds enumerated under said provision. Hence this case.
Whether the trial court correctly dismissed the action on the ground of laches without conducting trial on the merits.
No, the elements of laches must be proved positively. Laches is evidentiary in nature which could not be established by mere allegations in the pleadings and can not be resolved in a motion to dismiss. At this stage therefore, the dismissal of the complaint on the ground of laches is premature. Those issues must be resolved at the trial of the case on the merits wherein both parties will be given ample opportunity to prove their respective claims and defenses.
The elements of laches are: (1) conduct on the part of the defendant, or of one under whom he claims, giving rise to the situation of which the complaint seeks a remedy; (2) delay in asserting the complainant’s rights, the complainant having had knowledge or notice of the defendant’s conduct as having been afforded an opportunity to institute a suit; (3) lack of knowledge or notice on the part of the defendant that the complainant would assert the right in which he bases his suit; and (4) injury or prejudice to the defendant in the event relief is accorded to the complainant, or the suit is not held barred.
Whether or not the elements of laches are present is a question involving a factual determination by the trial court. There is no absolute rule as to what constitutes laches or staleness of demand; each case is to be determined according to its particular circumstances. Laches is not concerned with the mere lapse of time, rather, the party must have been afforded an opportunity to pursue his claim in order that the delay may sufficiently constitute laches. Without prejudging the instant case, an apparent delay in the enforcement of one’s claim does not automatically constitute laches. The party charged with negligence or omission in invoking his right must be afforded the opportunity to raise his defenses, which can be accommodated only in a contentious proceeding.