GR 148574; (October, 2005) (Digest)
G.R. No. 148574 October 11, 2005
Eugenio G. Palileo, et al. vs. National Irrigation Administration
FACTS
Petitioners are the registered owners of a parcel of land in Laguna, inherited from their mother. Respondent National Irrigation Administration (NIA) has occupied a portion of this land since 1956, having constructed an irrigation canal and later an access road. NIA claimed the property was acquired through expropriation proceedings pursuant to a 1958 court order, but petitioners asserted no compensation was ever paid. In 1994, after formal demands for rental compensation were refused, petitioners filed an action for recovery of possession with damages against NIA.
The Regional Trial Court ruled in favor of the petitioners, ordering NIA to pay ₱100,000 for its use of the land. On appeal, the Court of Appeals reversed this decision, dismissing the complaint. The appellate court found that the action was effectively one for inverse condemnation, which had already prescribed. Petitioners then elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the action filed by the petitioners for recovery of possession with damages had already prescribed.
RULING
Yes, the action had prescribed. The Supreme Court affirmed the Court of Appeals’ decision. The Court clarified that the petitioners’ action, while denominated as one for recovery of possession, was in substance a claim for just compensation for the taking of their property by the government. Since NIA’s occupation and use were pursuant to a claimed expropriation, the proper remedy was an action for inverse condemnation, not an accion publiciana.
The Court held that such an action for just compensation, being an action founded on an implied contract, prescribes in ten years from the time the right of action accrues. The accrual date was when the land was taken, which was in 1956 for the canal and 1983 for the road. The petitioners filed their complaint only in 1995, well beyond the ten-year prescriptive period. The Court rejected the argument that prescription did not apply because the property was registered under the Torrens system, ruling that prescription runs against registered owners. The claim, having been filed out of time, was therefore barred.