### Facts:
The case revolves around the testamentary disposition of Vicenta Alviar’s estate, initiated on September 14, 1955, with Edilberta Pandinco petitioning for its settlement (Special Proceeding No. 4749) in the Court of First Instance (now Regional Trial Court) of Biñan, Laguna. The will admitted to probate on July 8, 1957, identified Vicenta Alviar’s heirs, which included Elvira Pandinco and the petitioners among others. A project of partition was signed by all heirs on August 13, 1960, and approved by the probate court on August 29, 1960. On September 17, 1966, a subsequent order approved the petitioners’ shares’ transfer to respondent Elvira Pandinco.
Decades later, on August 18, 1995, the petitioners filed a motion to reopen the case and set aside the partition, alleging they had neither signed the partition project nor been informed of the orders validating the shares’ transfer. The lower court, on December 19, 1995, denied this motion citing estoppel by laches. The petitioners then sought recourse at the Court of Appeals, which dismissed their petition on December 27, 1996. The appellate court held that the proper recourse would have been a timely appeal against the probate court’s orders, which had become final and executory.
### Issues:
1. Whether the Court of Appeals erred in sustaining the probate court’s orders that had attained finality.
2. Whether the Court of Appeals was correct in finding that the proper remedy was an appeal, not a special civil action for certiorari.
3. Whether the doctrine of laches applies to the petitioners’ inaction.
### Court’s Decision:
The Supreme Court denied the petition, upholding the decisions of both the probate court and the Court of Appeals. The High Court emphasized that the orders from the probate court had become final due to the petitioners’ failure to file a timely appeal, thus precluding their reversal. Additionally, the Court underscored that the petitioners’ prolonged inaction and the application of the doctrine of laches barred them from challenging the orders. The principle of laches was deemed applicable as the petitioners exhibited a neglect to assert their rights for an unreasonable and unexplained length of time, leading to a presumption of abandonment or decline to assert said rights.
### Doctrine:
The Supreme Court reiterated the doctrine that the law aids the vigilant, not those who slumber on their rights (Vigilantibus, sed non dormientibus, jura subveniunt), highlighting the detrimental effect of laches on legal claims. Also, it affirmed that judgments or orders become final at a certain point to encourage public policy for the cessation of judicial controversies.
### Class Notes:
– **Key Concept of Laches:** Failure or neglect for an unreasonable amount of time to assert a right, leading to a presumption of abandonment.
– **Doctrine on Finality of Judgments:** Once a judgment becomes final, it is binding and conclusive, preventing re-litigation of the same issues.
– **Due Diligence:** Requirement for parties to exercise reasonable diligence in protecting their rights; lack thereof can lead to the presumption of the right’s abandonment.
– **Vigilance in Legal Rights:** The law favors those who are vigilant with their rights, not those who wait too long to assert them.
### Historical Background:
This case underscores the Philippine judiciary’s longstanding principle on the importance of timely appeals in contesting court orders and the consequences of neglecting such procedural remedies. It serves as a pivotal reminder of the balance between finality in legal contests and the equitable principles that govern Philippine jurisprudence, emphasizing the need for vigilance in upholding one’s legal rights within reasonable timelines.
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