Lopez v. Auditor General
REITERATIONFacts
The Antecedents: Petitioner Francisco Lopez is the registered owner of a parcel of land in Lopez, Quezon. In 1937, the municipal government of Lopez utilized a portion of this property for the construction of a road, which later became the Lopez-Calauag section of the Manila South Road. While Lopez claims he agreed to this use in exchange for a parcel of town property, no formal agreement or record of such an exchange exists in the municipal council's records. Procedural History: On May 2, 1959, Lopez filed a claim for compensation with the Highway District Engineer, asserting his property was taken without a deed of conveyance or right of way. This claim was denied due to prescription. A subsequent request for reconsideration was also denied by the Commissioner of Public Highways, with the concurrence of the Secretary of Public Works and Communications. Lopez then appealed to the Auditor General, who also denied the claim, citing the statute of limitations and the petitioner's failure to present the claim to the Auditor General's office or the Committee on Claims within the prescribed period. The Petition: Petitioner Francisco Lopez brought this case to the Supreme Court, challenging the denial of his claim primarily on the issue of prescription. He relies on the precedent set in Alfonso vs. Pasay City, which allowed recovery for land taken by the government for public use even after a significant lapse of time, arguing that registered lands are not subject to prescription and that equity demands compensation. The respondents, conversely, anchor their defense on Jaen vs. Agregado, asserting that an action to collect the price of land, where ownership has been transferred, is subject to a ten-year statute of limitations, which Lopez's claim has exceeded.
Issue(s)
Whether the petitioner's claim for the value of the land taken by the Government in 1937 is barred by the statute of limitations.
Ruling
The Supreme Court affirmed the decision of the Auditor General, holding that the petitioner's action to collect the price of the land is barred by the statute of limitations.
Ratio Decidendi
On Issue 1: Yes, the claim is barred by prescription. The Court distinguished this case from Alfonso v. Pasay City by noting that in Alfonso, the Government took property without first acquiring title through expropriation or negotiated sale, making the action to recover the land or its value imprescriptible. In the present case, the petitioner categorically admitted that he gave the portion of his property to the municipality in exchange for another piece of land. Under Philippine law, contracts are binding in whatever form they are entered into, and the exchange became valid and ownership was transferred to the municipality upon the delivery of possession in 1937. Because ownership had already transferred, the petitioner's remaining legal remedy was not the recovery of the property, but an action to collect the price or value of the land. Following the teaching in Jaen v. Agregado, an action to collect the price of property where title has already passed must be brought within ten years. Since the petitioner did not file his claim until 1959, which is twenty-two years after the transfer of ownership, the action has clearly prescribed under the statute of limitations.
Main Doctrine
An action to recover the price of private property taken by the Government for public use without first acquiring title thereto either through expropriation or negotiated sale does not prescribe. However, where private property is acquired by the Government and all that remains is the payment of the price, the owner's action to collect the price must be brought within ten years, otherwise it would be barred by the statute of limitations.