National Power Corporation v. Sps. Campos
REITERATIONFacts
1. The Antecedents: The respondents, Spouses Jose C. Campos, Jr. and Ma. Clara Lopez-Campos, are the owners of a 66,819-square meter parcel of land. In the mid-1970s, the National Power Corporation (NPC), through Dr. Paulo C. Campos, requested a temporary right-of-way over a portion of this property for the installation of wooden electrical posts and transmission lines to electrify Puerto Azul. The respondents granted this permission on the condition that the arrangement would be temporary and the posts would be relocated once permanent lines were installed. However, NPC continued to use the property without compensation. In 1994 and 1995, NPC agents trespassed on the property to conduct surveys for the installation of an all-steel transmission line tower, despite the respondents' refusal to grant permission. On December 12, 1995, NPC initiated an expropriation case for 5,320 square meters of the property, alleging failed negotiations, which the respondents denied. 2. Procedural History: The respondents filed a complaint for sum of money and damages against NPC on February 2, 1996. NPC's motion to dismiss was denied by the Regional Trial Court (RTC). Subsequently, NPC was declared in default for failing to file an answer. NPC's petition for certiorari, prohibition, and preliminary injunction with the Court of Appeals (CA) assailing the RTC's orders was dismissed. The RTC proceeded to hear the case ex parte and rendered a decision on September 26, 1996, ordering NPC to pay actual damages of P480,000.00, moral damages of P1,000,000.00, nominal damages of P500,000.00, and attorney's fees of P150,000.00. NPC appealed to the CA, which affirmed the RTC's decision on June 16, 2000, finding that the respondents' claim had not prescribed and that the damages awarded were just and reasonable. 3. The Petition: This case is a petition for review on certiorari filed by the National Power Corporation (NPC) before the Supreme Court. NPC seeks to reverse the decision of the Court of Appeals, arguing that the respondents' claim for compensation and damages had prescribed. NPC contends that it acquired an easement of right-of-way by prescription under Article 620 of the Civil Code, as the use of the property was continuous and apparent for over twenty-three years. NPC also invokes Section 3(i) of its Charter (Republic Act No. 6395) to assert that the respondents waived their right to claim compensation after five years. Furthermore, NPC challenges the award of nominal and moral damages, attorney's fees, and costs of litigation, asserting these claims also prescribed. The core of NPC's argument is that the respondents' action is barred by prescription, rendering the lower courts' decisions erroneous.
Issue(s)
Whether the Spouses Campos' claim for compensation and damages has prescribed, considering the applicability of Section 3(i) of NPC's Charter (R.A. No. 6395). Whether NPC acquired an easement of right-of-way by prescription. Whether the award of moral damages, nominal damages, attorney's fees, and costs of suit is proper.
Ruling
The petition is bereft of merit. The Supreme Court affirmed the decision of the Court of Appeals in toto, denying the petition for review and upholding the award of damages to the respondents.
Ratio Decidendi
On the issue of prescription and the applicability of Section 3(i) of NPC's Charter (R.A. No. 6395): The Supreme Court held that Section 3(i) of R.A. No. 6395, which provides a five-year prescriptive period for actions for compensation and/or damages, is not applicable in this case because NPC had not acquired title to the property. The Court reiterated the principle that where private property is taken by the government for public use without first acquiring title, the owner's action to recover compensation does not prescribe. The five-year prescriptive period only commences from the time NPC acquires title, which had not happened at the time of the filing of the action. On the issue of acquisition of easement by prescription: The Supreme Court held that NPC's claim of acquiring an easement of right-of-way by prescription under Article 620 of the Civil Code is untenable. Prescription requires possession under claim of title, which was absent here. The possession by NPC was merely upon the tolerance and tacit license of the Spouses Campos. Acts of possessory character executed by virtue of license or mere tolerance do not produce legal effects for the purpose of possession and prescription, as they are not considered possession en concepto de dueño (in the concept of an owner). Therefore, the permissive use by NPC, regardless of its duration, could not ripen into an easement by prescription. On the award of moral and nominal damages, attorney's fees, and costs: The Court found the award of moral damages proper. NPC's act of misrepresenting that negotiations took place, which affected the sale of the property to Solar Resources, Inc., caused mental anguish, moral shock, and wounded feelings to the Spouses Campos, who were individuals of high standing. This conduct fell under Article 21 of the Civil Code, which allows recovery for acts contrary to morals, good customs, or public policy. Nominal damages were also sustained as NPC's actions violated the Spouses Campos' proprietary rights by trespassing and attempting to deceive their caretaker. The award of attorney's fees was deemed just and equitable because NPC's actions compelled the Spouses Campos to litigate to protect their interests.
Main Doctrine
Possession of property merely upon the tolerance of the owner, no matter how long continued, will not ripen into an easement of right-of-way by prescription. Furthermore, claims for compensation and/or damages for the use of private property by the National Power Corporation do not prescribe until title to the property is acquired by the NPC, either through expropriation or negotiated sale.