Heirs of Rosa Dumaliang v. Damiano Serban

Summary

The Supreme Court reversed lower courts' dismissal of heirs' action for reconveyance based on laches. Petitioners inherited a 76,804 sq.m. lot but only sold 20,000 sq.m. in 1965. Respondents obtained title to the entire lot through an allegedly fraudulent 1962 deed signed by persons already deceased. Lower courts dismissed after 32 years, finding laches. The Supreme Court held that laches requires proof of four elements, particularly the plaintiff's knowledge of defendant's conduct, which was not established. Petitioners discovered the fraud only in 1992. If the deed was truly forged and void ab initio, the action for declaration of inexistence is imprescriptible under Article 1410 of the Civil Code. The case was remanded for trial on the merits, emphasizing that laches cannot defeat imprescriptible legal rights or perpetrate fraud and injustice.