FELICIANA EDRALIN, PETITIONER VS. ANDRES EDRALIN, ET AL., RESPONDENTS.

Feliciana Edralin versus Andres Edralin

The Case

This is a petition for review on certiorari brought by Feliciana Edralin against her brother Andres Edralin and his co-defendants, his daughter Isabel, his daughter Gregoria, and his daughter-in-law Gorgonia Dacuycuy-Edralin. Feliciana sued for the partition of ten parcels of irrigated riceland in Bacarra, Ilocos Norte, which she claimed she and her brother owned in common, and for the recovery of her share in the yearly canon of those lands. The case matters because it shows how the Supreme Court treats a claim of co-ownership that rests on doubtful entries in an association's books and is asserted only after forty-four years of silence, and because it states plainly the rule on the conclusiveness of the facts found by the Court of Appeals.

Procedural History

Feliciana Edralin filed her complaint in May 1952 before the Court of First Instance of Ilocos Norte. After trial, the trial court rendered judgment in January 1954. It found that the parcels of land belonged neither to the plaintiff nor to Andres Edralin but to the association, and it held that an action for partition was therefore improper. On the theory, however, that the brother and sister had bought the usufructuary rights over the lands share and share alike, it declared the plaintiff entitled to work and cultivate one half of the ten parcels, and it ordered Andres to pay her damages in palay or its equivalent value every year since the agricultural year 1944 to 1945.

Andres Edralin appealed to the Court of Appeals. That court reversed the judgment and dismissed the complaint, holding that Andres Edralin alone re-acquired the share that originally belonged to their grandfather, Nicolas Edralin. Feliciana then came to the Supreme Court through a petition for review on certiorari, contending that the finding of the Court of Appeals was a conclusion not supported by the evidence.

Facts

As early as 1878 there existed in Bacarra, Ilocos Norte, an association of irrigators called the Asociacion Zanjera de Santo Rosario Mamutbut. It kept books listing its members. A member, man or woman, had to dig and maintain the canals of the communal irrigation system, as often as necessary and up to one hundred days every year, either in person or through a substitute. In return, each enrolled member received a share of association land called a tugao, usually about one hectare of riceland, which the member tilled and whose products he enjoyed, and which he could declare for taxation and hold as owner for as long as he fulfilled his duties. A member who violated the rules could be expelled, and his tugao would return to the association for redistribution.

Nicolas Edralin and Gregoria Albano, husband and wife, were originally members of record, each with a separate share. Gregoria's share was abandoned and reverted to the association. When Nicolas died, his portion was worked by his son Antero, who committed infractions of the rules and was removed from the group of irrigators, so that share too was forfeited. In 1908 Andres Edralin asked the association to give him the forfeited share of his grandfather, and he said that the share of his grandfather should be revived by him while the share of his grandmother should be revived by his sister Feliciana. The amount required for admission as a member was 90 pesos. Fifty pesos were paid in May 1908, entered in the association's book in the names of both Andres and Feliciana, and the balance of 40 pesos was paid in April and July 1909, exclusively in the name of Andres. Immediately after the first payment, the name of Andres Edralin was entered in the rolls of the association as a member.

From 1908 onward Andres was in possession of the lands. He declared them for taxation exclusively in his name as early as 1911 and paid the taxes without protest from Feliciana. The work on the land was always done by him for his own account, and Feliciana never intervened in the division of the produce, which the defendants appropriated solely. In 1937 the brother and sister executed an extra-judicial partition of their common properties, and the lands in question, or at least their rights therein, were not included. Only in May 1952, more than forty years after Andres was admitted as a member, did Feliciana file her action for partition.

Issues

• Whether or not the Court of Appeals erred in holding that Andres Edralin alone re-acquired the forfeited tugao of Nicolas Edralin, despite the entries in the association's book naming both Andres and Feliciana in the first payments of the entrance fee.
• Whether or not the findings of fact of the Court of Appeals may be reviewed by the Supreme Court.
• Whether or not the plaintiff's claim is barred by laches or unreasonable delay in asserting her right.

Applicable Provisions

This decision does not quote or construe any statutory provision. It rests on the rules of evidence and on equity. The governing principle it applies is the rule on the conclusiveness of the findings of fact of the Court of Appeals, and the equitable doctrine of laches, which the Court states in the words of an earlier decision:

The assertion of doubtful claims, after long delay, cannot be favored by the courts. Time inevitably tends to obliterate occurrences from the memory of witnesses, and even where the recollection appears to be entirely clear, the true clue to the solution of a case may be hopelessly lost. These considerations constitute one of the pillars of the doctrine long familiar in equity jurisprudence to the effect that laches or unreasonable delay on the part of a plaintiff in seeking to enforce a right is not only persuasive of a want of merit but may, according to the circumstances, be destructive of the right itself. Vigilantibus non dormientibus equites subvenit.

This passage bears directly on the case because Feliciana slept on her claim for forty-four years, and the Court used that delay as a reason to doubt the merit of her claim.

Ruling

On the first issue, the Court held that the petition is without merit. The Court of Appeals had expressly found that the full entrance fee of 90 pesos was paid by Andres Edralin and that only he became the registered member of the association in respect of the lands in question. While the first payments in 1908, amounting to 50 pesos, were entered in the book in the names of both Andres and Feliciana, those entries were found by the Court of Appeals to have been made by mistake, and that finding is borne out by the record, because the subsequent payments were made exclusively in the name of Andres. From 1908 onward Andres possessed the lands, declared them for taxation in his name as early as 1911, paid the taxes without protest, did all the work for his own account, and appropriated the produce exclusively.

On the second issue, the Court held that these facts, found by the Court of Appeals to be either undisputed or established by the evidence, are conclusive and cannot be reviewed by the Supreme Court.

On the third issue, the Court held that there was good reason to doubt the merit of the plaintiff's claims. From 1908 up to the filing of the complaint in 1952, some 44 years had elapsed during which she took no steps to assert her right. Her claims were further weakened by the fact that in the 1937 extra-judicial partition of their common properties, the lands in question, or at least their rights therein, were not included. These circumstances, as the Court of Appeals observed, militate against the genuineness of her claims, and the Court quoted with approval the doctrine that laches or unreasonable delay is not only persuasive of a want of merit but may be destructive of the right itself.

Doctrine

A Bar candidate should retain three rules from this case. First, the findings of fact of the Court of Appeals, when either undisputed or established by the evidence, are conclusive and cannot be reviewed by the Supreme Court in a petition for review on certiorari. Second, entries in the books of an association that are shown to have been made by mistake do not create rights in the person named, especially where all subsequent acts, such as later payments, tax declarations, possession, and the appropriation of the produce, point to one person alone as the owner. Third, laches, or unreasonable delay in asserting a right, is not only persuasive of a want of merit but may, according to the circumstances, be destructive of the right itself, as the Court states in the quoted passage, and the maxim vigilantibus non dormientibus equites subvenit, meaning that equity aids the vigilant and not those who sleep on their rights, expresses the same principle.

Disposition

The Supreme Court affirmed the decision of the Court of Appeals, dismissed the complaint, and ordered the petitioner to pay the costs.

Remember This

Memorize the line that the assertion of doubtful claims after long delay cannot be favored by the courts, and that laches may be destructive of the right itself. Examiners like to use this case on the conclusiveness of the facts found by the Court of Appeals and on laches as a defense against stale claims of co-ownership.