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INSURANCE OF PHILIPPINE ISLANDS CORPORATION v. SPS. VIDAL S. GREGORIO AND JULITA GREGORIO

This case has been cited 1 times or more.

2014-07-30
PERLAS-BERNABE, J.
Finally, the Court cannot subscribe to RBCI's contention that respondents are barred by laches from laying claim over the subject properties in view of their inexplicable inaction from the time they learned of the falsification. Laches is principally a doctrine of equity. It is negligence or omission to assert a right within a reasonable time, warranting a presumption that the party entitled to assert it either has abandoned or declined to assert it.[73] In this case, the complaint for nullification of the SPA was filed before the RTC on April 17, 1996, or barely three years from respondents' discovery of the averred forgery in 1993, which is within the four-year prescriptive period provided under Article 1146[74] of the Civil Code to institute an action upon the injury to their rights over the subject properties. A delay within the prescriptive period is sanctioned by law and is not considered to be a delay that would bar relief. Laches applies only in the absence of a statutory prescriptive period.[75] Furthermore, the doctrine of laches cannot be used to defeat justice or perpetrate fraud and injustice. It is the more prudent rule that courts, under the principle of equity, will not be guided or bound strictly by the statute of limitations or the doctrine of laches when by doing so, manifest wrong or injustice would result,[76] as in this case.