- Petitioner
- Leopoldo C. Leonardo
- Respondent
- Virginia Torres Maravilla
- Citation
- G.R. No. 143369
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ynares-Santiago, J.
- Decided
- November 27, 2002
Summary
The Supreme Court affirmed dismissal of petitioner's complaint for delivery of property and damages on grounds of prescription and laches. Petitioner claimed ownership of a Pasay City lot based on 1972 deeds of sale, but never took possession. The Court ruled this was an action for specific performance of written contract, not recovery of ownership, since no delivery occurred under Article 1498 of the Civil Code. The action was barred by the 10-year prescriptive period under Article 1144, having been filed 21 years after the right accrued. The Court emphasized that ownership does not pass by mere stipulation but requires delivery, and petitioner's 21-year delay constituted laches. Registration of adverse claim does not toll the prescriptive period.
Intellegal Wiki · Key Holding
Affirmed the CA: without delivery, ownership never passed under Article 1498, so the action was for specific performance barred by the 10-year period of Article 1144 and by 21 years' laches.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.