G.R. No. 209435. August 10, 2022 (Case Brief / Digest)

### Title:
**Ernesto Lorenzo et al. vs. Fortunata D. Eustaquio and Children**

### Facts:
In 1942, the spouses Gregorio Eustaquio and Regina Lorenzo executed a deed of donation propter nuptias in favor of Delfin Eustaquio and Fortunata, donating a parcel of land among other gifts for their marriage. Delfin and Fortunata occupied and possessed the land in question until Delfin’s death in 1994.

The petitioners, being the heirs of Gregorio and Regina Eustaquio’s other children, presented a Deed of Succession and Adjudication in 1993, claiming parts of the land based on a dubious document. This led the respondents, heirs of Delfin, to file a complaint for quieting of title and other reliefs against the petitioners, asserting ownership through the donation and questioning the validity of the petitioners’ documents. The trial court ruled in favor of the respondents, a decision affirmed by the Court of Appeals and brought to the Supreme Court on certiorari by the petitioners.

### Issues:
1. Whether the lack of a subject index in the appellant’s brief is grounds for dismissal of their appeal.
2. Ownership of the subject land.
3. Validity of the Deed of Succession and Adjudication.
4. Entitlement of respondents to damages.

### Court’s Decision:
The Supreme Court denied the petition for lack of merit, affirming the CA’s decision. It held that the procedural defect (lack of a subject index) warranted dismissal of the appeal. On substantive grounds, the Court ruled that the Eigustaquio heirs established ownership not by acquisitive prescription, but through laches, as the property in question is registered and not subject to prescription. The Court declared the donation propter nuptias void for not being in a public instrument as required, but recognized that possession and the principle of laches conferred ownership to the respondents. The Deed of Succession and Adjudication was declared null, and the award of damages to the respondents was upheld.

### Doctrine:
Ownership of registered land cannot be acquired by prescription, but a party’s failure to assert a right over registered land for an unreasonable length of time can lead to a loss of that right through laches.

### Class Notes:
1. **Prescription vs. Laches**:
– Prescription refers to the acquisition or loss of rights through the passage of time as dictated by law.
– Laches pertains to the loss of a right due to a prolonged failure to enforce it, which results in prejudice to the other party.

2. **Donation Propter Nuptias**:
– Must be made in a public instrument to be valid.

3. **Torrens System Land**:
– Land registered under the Torrens system is not subject to acquisitive prescription.

4. **Doctrine of Laches**:
– Can result in the loss of rights over registered land if one fails to assert them over an extended period, leading to prejudice against the party in possession.

### Historical Background:
This case illustrates the Philippines’ legal principles surrounding land ownership, donations propter nuptias, and the distinction between prescription and laches in the context of property law. It underscores the importance of diligence and proper documentation in asserting property rights, especially concerning registered lands under the Torrens system.


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