G.R. No. L-48610. March 31, 1987.
SOLEDAD PROVIDO, plaintiff-appellant, vs. OCTAVIO ACENAS, NATIONAL DEVELOPMENT CO. and DOLE (PHILIPPINES) INC., defendants-appellees.

FACTS

Plaintiff-appellant Soledad Provido was a homestead patentee of a lot in South Cotabato. On October 15, 1963, she sold this homestead to defendant Octavio Acenas. In 1966, Acenas sold the property to the National Development Company (NDC), which subsequently leased it to Dole (Philippines), Inc. On September 19, 1968, within five years from the 1963 sale, Provido filed an action against Acenas in the Court of First Instance of Cotabato to exercise her legal right of repurchase under Section 119 of the Public Land Act.
In his answer, Acenas admitted the sale but asserted he no longer owned the property, having sold it to NDC. Provido then sought and was granted leave to amend her complaint to implead NDC and Dole as indispensable parties. The amended complaint was filed on December 24, 1968. NDC and Dole filed separate motions to dismiss, arguing the action against them was barred by the statute of limitations, as the amended complaint was filed more than five years after the original 1963 conveyance. The trial court granted the motions and dismissed the case against NDC and Dole.

ISSUE

Whether the action for legal redemption against NDC and Dole had prescribed, considering the amended complaint impleading them was filed more than five years after the original sale, but the original complaint against the first vendee was filed within the prescriptive period.

RULING

The Supreme Court reversed the trial court’s orders of dismissal and remanded the case for trial on the merits. The Court held that Provido’s right of repurchase had not prescribed against NDC and Dole. The legal logic is anchored on the doctrine that the filing of an amended complaint, which merely adds indispensable parties, relates back to the date of the filing of the original complaint for purposes of determining prescription.
The original complaint filed against Acenas on September 19, 1968, was unquestionably within the five-year prescriptive period from the October 15, 1963 sale. This complaint stated a valid cause of action under Section 119 of the Public Land Act. The subsequent amendment to include NDC and Dole did not constitute a new action. Instead, it retroacted to the date of the original filing, as established in Pangasinan Transportation Co. vs. Philippine Farming Co., Ltd. This is because NDC and Dole, as successors-in-interest to Acenas, merely stepped into his shoes. They cannot accept the benefits of the transaction from their predecessor while simultaneously disclaiming the associated burdens, such as the homesteader’s subsisting right of repurchase. To hold otherwise would allow a series of vendees to defeat the statutory right through successive transfers. The Court also noted that the action against the successors was not an admission of the validity of their titles but a necessary step to fully adjudicate the repurchase right, with them being indispensable parties.