Delia Bailon-Casilao v. The Honorable Court of Appeals

Summary

This case involves a dispute over a 48,849 square meter registered land among co-owners when two co-owners sold the entire property without consent of the other four co-owners. The Supreme Court ruled that such sales affect only the sellers' proportionate shares, making the buyer a co-owner rather than sole owner. The Court held that the proper remedy is partition under Rule 69, not recovery of possession. Significantly, the Court rejected both prescription and laches defenses, ruling that partition actions are imprescriptible under Article 494 of the Civil Code, registered lands under the Torrens system cannot be lost by prescription, and laches cannot apply when the aggrieved co-owners had no knowledge of the unauthorized sale and immediately filed suit upon discovery. The decision reinforced the protection of co-ownership rights and the integrity of the Torrens land registration system.