Garcia v. Auditor General
REITERATIONFacts
The Antecedents: Petitioners-appellants filed two claims with the Office of the Auditor General for payment of portions of their properties allegedly taken and used by the Government for the widening of Uyanguren Street in Davao City in 1953. One claim was by Milagros Vda. de Garcia for P190,240.00 for 2,378 sq. m. from Lot No. 1, PNC154. The other claim was by Milagros Vda. de Garcia and her children, as heirs of Leon A. Garcia, Sr., for P161,942.40 for 2,024.28 sq. m. from Lots Nos. 181-B-2-C and 181-B-2-B. The total area allegedly taken was 4,402.28 sq. m., which petitioners claimed was used to widen Uyanguren Street from 10 meters to 15 meters in 1953. Petitioners presented titles showing the street's width as 10 meters, a map showing irregular alignments, and affidavits of residents attesting to the 10-meter width before a December 1952 fire. They also claimed to have paid realty taxes for the portions taken until 1953 and excluded them thereafter. A document granting a road-right-of-way to the City of Davao was also presented. Procedural History: The Auditor General denied the claims in a decision dated May 15, 1964, ruling that Uyanguren Street already had a 15-meter width before World War II and even at its construction before 1918. The Auditor General presumed that the predecessors-in-interest had ceded the road-right-of-way and that the claims, if any, had prescribed. Petitioners' Motion for Reconsideration and Supplemental Motion for Reconsideration were denied on October 10, 1966. This led to the present petition for review. The Petition: Petitioners-appellants sought a review of the Auditor General's decision, questioning whether the ruling that Uyanguren Street had a 15-meter width since its construction before 1918 and remained so before the issuance of the Torrens Certificates of Titles was supported by substantial evidence.
Issue(s)
Whether the ruling of the General Auditing Office that Uyanguren Street, at the time of its construction sometime before 1918, was 15 meters wide and remained as such before the issuance of the Torrens Certificates of Titles covering the lands of the herein petitioners bordering the street in question, is supported by substantial evidence. Whether the claims for payment for portions of land allegedly taken for street widening had prescribed.
Ruling
The Supreme Court affirmed the decision of the Auditor General, denying the claims for payment. The Court found that Uyanguren Street existed with a 15-meter width since before 1918, prior to the issuance of the Torrens Titles from which the petitioners' titles were derived. The Court also held that the claims had prescribed, as the street existed as a public thoroughfare before the issuance of the titles.
Ratio Decidendi
On the width of Uyanguren Street: The Supreme Court found that the ruling of the Auditor General that Uyanguren Street had a 15-meter width since its construction before 1918 was supported by substantial evidence. The Court noted that the street existed long before the issuance of Original Certificates of Titles Nos. 40 and 74 in 1921, from which the petitioners' Transfer Certificates of Titles were derived. The objecting public officials presented evidence, including Resolution No. 25 of the Davao City Appraisal Committee, official communications from the Davao City Engineer, and pre-war plans, all attesting that Uyanguren Street was constructed before the last World War with a standard 15-meter width and had not undergone any widening since its construction. The Court found no flaw in the Auditor General's findings of fact, which were adequately supported by evidence. On the issue of prescription: The Supreme Court held that while prescription generally does not prevail against a Torrens Title, in this case, Uyanguren Street existed long before the issuance of the Original Certificates of Titles in 1921. Consequently, the petitioners' titles, derived from these original titles, could not and did not include such public thoroughfares that were already in existence. The Court cited Section 39 of the Land Registration Act (No. 496) and the case of Jaime Rosario vs. Auditor General (No. L-11817, April 30, 1958) to support the principle that Torrens Titles do not extend to public lands or public thoroughfares already in existence at the time of the title's issuance. Therefore, the claims for compensation for these portions had prescribed.
Main Doctrine
The claims for payment for portions of land allegedly taken for street widening were denied as the street was found to have existed with its standard width prior to the issuance of the Torrens Titles, and the claims had prescribed.