Provido v. Acenas
REITERATIONFacts
1. The Antecedents: Plaintiff-appellant Soledad Provido was granted a homestead patent over Lot No. 58, Pis-247-D, in South Cotabato, covered by OCT No. V-19264. On October 15, 1963, Provido sold this land. Subsequently, in 1966, the buyer, Octavio Acenas, sold the land to the National Development Company (NDC), which then leased it to Dole (Philippines), Inc. under a Grower Agreement. Provido sought to exercise her right of repurchase under Section 119 of Commonwealth Act No. 141, the Public Land Act. 2. Procedural History: On September 19, 1968, Provido filed an action against Octavio Acenas in the Court of First Instance (CFI) of Cotabato, seeking to repurchase the property. Acenas filed an answer, admitting he no longer owned the property as he had sold it to NDC in 1966. Provido then amended her complaint to implead NDC and Dole. Both NDC and Dole filed motions to dismiss, arguing the claim was barred by the statute of limitations and stated no cause of action. The CFI dismissed the case against NDC and Dole. Provido's motion for reconsideration was denied, leading to this appeal. 3. The Petition: The plaintiff-appellant's sole assignment of error is that the lower court erred in dismissing the complaint on the ground of prescription of action. The core issue is whether Provido lost her right to repurchase the homestead within the five-year period stipulated in Section 119 of the Public Land Act. Provido contends that her action, filed on September 19, 1968, was within the five-year period, and the filing of the original complaint suspended the prescriptive period. She further argues that NDC, as a successor-in-interest, is bound by the same repurchase conditions and that the action against Acenas also interrupts prescription against NDC. NDC and Dole counter that the amended complaint impleading them was filed beyond the five-year period, and that Provido had constructive knowledge of the sale to NDC through its registration and the issuance of a new title.
Issue(s)
Whether the plaintiff-appellant lost her right to repurchase the homestead. Whether the filing of the amended complaint against NDC and Dole retroacted to the filing of the original complaint against Acenas for purposes of prescription.
Ruling
The assailed Orders dated September 5, 1970, September 19, 1970, and December 2, 1970, of the trial court are SET ASIDE. The case is REMANDED to the court a quo for trial on the merits.
Ratio Decidendi
On whether the plaintiff-appellant lost her right to repurchase the homestead: The Court held that the plaintiff-appellant had not lost her right to repurchase. The original complaint clearly stated a cause of action against Acenas for the exercise of the right of repurchase within the five-year period provided by law. The subsequent sale of the property by Acenas to NDC, as alleged in his answer, was of no consequence in determining whether the complaint itself stated a cause of action. The right of repurchase is a statutory right intended to give the homesteader a chance to preserve the land granted by the State, and this right is a matter of public policy. The Court emphasized that NDC, as a successor-in-interest, could not be in a better position than its predecessor, Acenas, and that the action against Acenas also interrupted the prescriptive period against NDC. On whether the filing of the amended complaint against NDC and Dole retroacted to the filing of the original complaint against Acenas for purposes of prescription: The Court ruled in the affirmative. Even if the registration of the sale to NDC occurred on July 9, 1965, and was constructively known by the appellant, the principle that the filing of an amended complaint retroacts to the date of the original complaint applies. This principle is crucial when the original complaint sufficiently states a cause of action. Therefore, the filing of the amended complaint against NDC and Dole, even though they were not original defendants, was legally effectuated upon the filing of the original complaint, which was within the prescribed five-year period. The Court found it inequitable for NDC and Dole to invoke their rights as successors-in-interest while disclaiming the effects of that relationship when disadvantageous. The impleading of NDC and Dole was not an admission of the validity of their titles but a necessity for the complete disposition of the lot if the appellant's claim proved valid.
Main Doctrine
The filing of an amended complaint, even if it impleads new parties, retroacts to the date of the filing of the original complaint for purposes of prescription, provided the original complaint sufficiently stated a cause of action against the original defendant.