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ANTONIO R. AGRA v. PHILIPPINE NATIONAL BANK

This case has been cited 9 times or more.

	GR No. 193821 2015-11-23	PHIL-AIR CONDITIONING CENTER v. RCJ LINES BRION, J.
On the one hand, the question of laches is addressed to the sound discretion of the court.[43] The court resolves whether the claimant asserted its claim within a reasonable time and whether its failure to do so warrants the presumption that it either has abandoned it or declined to assert it. The court determines the claimant's intent to assert its claim based on its past actions or lack of action. After all, what is invoked in instances where a party raises laches as a defense is the equity jurisdiction of the court.[44]
	GR No. 190755 2010-11-24	LAND BANK OF PHILIPPINES v. ALFREDO ONG VELASCO JR., J.
Land Bank posits as a defense that it did not unduly enrich itself at Alfredo's expense during the foreclosure of the mortgaged properties, since it tendered its bid by subtracting PhP 750,000 from the Spouses Sy's outstanding loan obligation. It is observed that this is the first time Land Bank is revealing this defense. However, issues, arguments, theories, and causes not raised below may no longer be posed on appeal.[25] Land Bank's contention, thus, cannot be entertained at this point.
	GR No. 176664 2008-07-21	BANK OF PHILIPPINE ISLANDS v. SPS. REYNALDO NACHURA, J.
Finally, the respondents posit that the petitioner's claim is barred by laches since it has been three years since the checks were issued. We do not agree. Laches is a recourse in equity. Equity, however, is applied only in the absence, never in contravention, of statutory law. Thus, laches cannot, as a rule, abate a collection suit filed within the prescriptive period mandated by the New Civil Code.[31] The petitioner's action was filed within the ten-year prescriptive period provided under Article 1144 of the New Civil Code. Hence, there is no room for the application of laches.
	GR NO. 167022 2007-08-31	LICOMCEN INCORPORATED v. FOUNDATION SPECIALISTS NACHURA, J.
Indeed, FSI filed its petition for arbitration only on October 8, 2002, or after the lapse of more than four years since the project was "indefinitely suspended." But we agree with the CIAC and the CA that such delay can hardly be considered unreasonable to give rise to the conclusion that FSI already abandoned its claim. On the contrary, the delay was due to the fact that FSI exerted efforts to have the claim settled extra- judicially which LICOMCEN rebuffed. Besides, except for LICOMCEN's allegation that the filing of the suit is already barred by laches, no proof was offered to show that the filing of the suit was iniquitous or unfair to LICOMCEN. We reiterate that, unless reasons of inequitable proportions are adduced, a delay within the prescriptive period is sanctioned by law and is not to be considered delay that would bar relief.[47] In the instant case, FSI filed its claim well within the ten-year prescriptive period provided for in Article 1144 of the Civil Code.[48] Therefore, laches cannot be invoked to bar FSI from instituting this suit.
	GR NO. 169356 2007-08-28	CARMEN FANGONIL - HERRERA v. TOMAS FANGONIL CHICO-NAZARIO, J.
On the matter of laches, we find no sufficient cause to apply the principle of laches, it being a principle grounded on equity. Laches is the failure or neglect, for an unreasonable and unexplained length of time, to do that which, by exercising due diligence, could or should have been done earlier; it is negligence or omission to assert a right within a reasonable time, warranting the presumption that the party entitled to assert it either has abandoned or declined to assert it.[40] Several circumstances must be present. First, there should exist conduct on the part of the defendant or one under whom he claims, giving rise to the situation of which complaint is made and for which the complainant seeks a remedy. Second, there is delay in asserting the complainant's right, the complainant having had knowledge or notice of defendant's conduct and having been afforded an opportunity to institute a suit. Third, defendant had no knowledge or notice that the complainant would assert the right on which he bases his claim. Fourth, the defendant will suffer injury or prejudice in the event relief is accorded the complainant, or the suit is not held barred. Petitioner failed to prove the presence of all four established requisites of laches. Moreover, there is no absolute rule as to what constitutes laches or staleness of demand; each case is to be determined according to its particular circumstances, with the question of laches addressed to the sound discretion of the court.[41] Because laches is an equitable doctrine, its application is controlled by equitable considerations and should not be used to defeat justice or to perpetuate fraud or injustice.[42]
	GR NO. 143188 2007-02-14	FLORENTINO PINEDA v. HEIRS OF ELISEO GUEVARA TINGA, J.
Whether or not the elements of laches are present is a question involving a factual determination by the trial court. There is no absolute rule as to what constitutes laches or staleness of demand; each case is to be determined according to its particular circumstances.[10] Laches is not concerned with the mere lapse of time, rather, the party must have been afforded an opportunity to pursue his claim in order that the delay may sufficiently constitute laches.[11] Without prejudging the instant case, an apparent delay in the enforcement of one's claim does not automatically constitute laches. The party charged with negligence or omission in invoking his right must be afforded the opportunity to raise his defenses, which can be accommodated only in a contentious proceeding.
	GR NO. 125851 2006-07-11	ALLIED BANKING CORPORATION v. CA QUISUMBING, J.
Last, we find the defense of laches unavailing. The question of laches is addressed to the sound discretion of the court and since laches is an equitable doctrine, its application is controlled by equitable considerations.[23] Respondents, however, failed to show that the collection suit against them as sureties was inequitable. Remedies in equity address only situations tainted with inequity, not those expressly governed by statutes.[24]
	GR No. 149750 2003-06-16	AURORA ALCANTARA-DAUS v. SPS. HERMOSO AND SOCORRO DE LEON PANGANIBAN, J.
On the claim of laches, we find no reason to reverse the ruling of the CA. Laches is based upon equity and the public policy of discouraging stale claims.[34] Since laches is an equitable doctrine, its application is controlled by equitable considerations.[35] It cannot be used to defeat justice or to perpetuate fraud and injustice.[36] Thus, the assertion of laches to thwart the claim of respondents is foreclosed, because the Deed upon which petitioner bases her claim is a forgery.
	GR No. 149679 2003-05-30	HEIRS OF CLEMENTE ERMAC v. ERMAC PANGANIBAN, J.
Because laches is an equitable doctrine, its application is controlled by equitable considerations.[23] It cannot be used to defeat justice or to perpetuate fraud and injustice.[24] Its application should not prevent the rightful owners of a property to recover what has been fraudulently registered in the name of another.