Jose Manuel Stilianopulos v. The City of Legaspi

Summary

Stilianopulos sought annulment of 1964 reconstitution order that granted OCT No. 665 to City of Legaspi over disputed Lot 1, claiming extrinsic fraud and lack of jurisdiction. He alleged City failed to notify his family during reconstitution proceedings and that the lot was never covered by original title but derived from 1953 consolidation-subdivision. Supreme Court found extrinsic fraud present but ruled the four-year prescriptive period had lapsed since petitioner should have discovered the fraud in 1970 when quieting of title case was filed. Court also applied laches for the 24-year delay and res judicata since the same ownership issues were already litigated in the quieting of title case. The decision demonstrates that even jurisdictional defects can be waived by laches, and that annulment actions have strict time limits that cannot be circumvented by filing different types of cases on the same subject matter.