Buenaventura v. Auditor General
REITERATIONFacts
The Antecedents: Petitioners, heirs of Daniel T. Tirona, sought compensation for two lots (Lot No. 5 and Lot No. 6), totaling 12,045 square meters, occupied by the National Government for a national highway built in 1917. The lots were covered by Original Certificates of Title issued in 1916 in the name of Daniel T. Tirona. No annotation in favor of the government appeared on the original certificates, and the heirs continued to pay real estate taxes. Procedural History: In 1952, the heirs complained to the District Engineer regarding the non-payment for their lots. Negotiations for a right-of-way agreement failed. In 1960, the claim was submitted to the Auditor General, who rejected it in a decision dated March 9, 1963, on the grounds of presumed prior consent and payment, and prescription of the claim. The Petition: The heirs appealed the Auditor General's decision to the Supreme Court.
Issue(s)
Whether the presumption of regularity in the conduct of business applies to the Government's occupation of registered private land without proper annotation. Whether the claim for compensation for the occupied land has prescribed.
Ruling
The Supreme Court reversed the decision of the Auditor General. It directed the Government to pay the claimants the assessed value of the lots in 1917, plus the amount of real estate taxes paid by them on the said lots.
Ratio Decidendi
On the presumption of regularity and the Torrens System: The Court held that the presumption of regularity in the conduct of business is not applicable in this case. The land in question was registered under the Torrens system since 1916, meaning no conveyance could affect it without proper recording and annotation in the office of the Register of Deeds. The admitted absence of any such entry or annotation on the original certificates of title, and the certification from the Register of Deeds, rebutted the presumption that the government had obtained prior consent and made payment. The Court emphasized that ordinary business practice dictates that a deed of conveyance, if executed, would be recorded, showing whether payment was made. The absence of any record of conveyance, whether by sale or donation, meant the burden of proving such conveyance and payment rested upon the Government. The Court noted that even a gratuitous conveyance of immovable property requires a public document and subsequent recording to affect the land under the Land Registration Act. On the issue of prescription: The Court reiterated its established exception to the rule on prescription, which applies in cases where the Government takes possession of private registered lands without paying compensation. In such instances, the duty to pay for the land subsists, irrespective of the passage of time. The Court cited previous rulings in Herrera vs. Auditor General and Alfonso vs. Pasay City, where it was held that registered lands are not subject to prescription, and that equity demands the government to pay for private property it appropriates for public benefit, regardless of the time elapsed. The Court found the Auditor General's attempt to distinguish the present case based on the timing of the road construction relative to the title issuance to be without merit, as the land was registered prior to the road's construction.
Main Doctrine
The Government's obligation to pay for private registered land it occupies for public use subsists regardless of the passage of time, and the presumption of regularity in the conduct of business does not apply when the conveyance is not recorded under the Torrens system.