Ongsiaco v. Dallo
REITERATIONFacts
The Antecedents: Private respondents (plaintiffs below) filed a complaint against petitioners (defendants below) for ownership of a parcel of land situated in Cuyapo, Nueva Ecija, with an area of 255 hectares. They prayed for the surrender of possession and payment of damages. The disputed parcel was described as "LOT X". Procedural History: Petitioners moved to dismiss the complaint on grounds of statute of limitations, lack of jurisdiction, no cause of action, and bar by prior judgments and resolutions. The respondent Court of First Instance denied the motion to dismiss, stating that the cause of action appeared to be different from prior cases and that the allegation of encroachment was a matter of evidence. However, the order did not resolve the plea of prescription. The Petition: Petitioners filed a petition for certiorari to set aside the order of denial and the subsequent order denying their motion for reconsideration, arguing that the respondent Court's failure to resolve the issue of prescription constituted a grave abuse of discretion.
Issue(s)
Whether the respondent Court committed a grave abuse of discretion in failing to resolve the issue of prescription. Whether the action filed by the private respondents is barred by prescription.
Ruling
The Supreme Court granted the writ of certiorari, set aside the assailed orders, and ordered the dismissal of the complaint filed by the private respondents.
Ratio Decidendi
On the issue of prescription and grave abuse of discretion: The Court held that the failure of the respondent Court to resolve the issue of prescription, which was a decisive ground for dismissal, constituted a grave abuse of discretion correctible by certiorari. The complaint itself alleged that the defendants had been in possession of the land in question since 1924, which was forty-two years prior to the filing of the complaint in 1966. This possession was described as adverse and in concept of owner, even if allegedly in bad faith. Under the Code of Civil Procedure then in force, adverse possession, regardless of good or bad faith, ripened into ownership after ten years. Similarly, an action to recover title to or possession of immovable property prescribed within the same ten-year period. Therefore, the action was clearly barred by prescription. The Court further noted that even under the new Civil Code, the thirty-year period for extraordinary prescription or extinction of the right of action over immovables had also expired. On the issue of res judicata: While the respondent Court's order did not explicitly rule on the plea of res judicata, the Court found the issue of prescription to be decisive. The voluminous pleadings concerning res judicata, particularly the identity of the land involved in previous litigations, were rendered moot by the clear bar of prescription. The Court emphasized that the failure to resolve prescription was the primary ground for granting the petition.
Main Doctrine
The failure of a respondent court to resolve the issue of prescription, which is decisive of the case, constitutes a grave abuse of discretion correctible by certiorari. Adverse possession, whether in good or bad faith, ripens into ownership after ten years under the Code of Civil Procedure, and an action to recover title or possession of immovable property also prescribes in the same period.