Heirs of Ferrer v. National Power Corporation
REITERATIONFacts
1. The Antecedents: The petitioners, heirs of spouses Crispulo Ferrer and Engracia Puhawan, initiated an injunction suit against the National Power Corporation (Napocor). They claimed ownership over portions of Lot 1873 and Lot 72, where Napocor had constructed the Caliraya Hydroelectric Power Plant. The petitioners also sought damages from Napocor for the use and occupation of these lots since 1936. Napocor contested these claims, asserting it acquired portions of Lot 1873 through purchase from Oliva Ferrer, a co-heir, and that its right to occupy Lot 72 stemmed from a Right of Way Agreement with the petitioners' predecessors. 2. Procedural History: The Regional Trial Court (RTC) dismissed the petitioners' action for injunction and damages, finding their claims insufficient. The RTC ruled that Napocor presented valid deeds of sale for Lot 1873 and that a valid right of way agreement existed for Lot 72. The Court of Appeals (CA) affirmed the RTC's decision, and subsequently denied the petitioners' motion for reconsideration. The petitioners then filed a petition for certiorari with the Supreme Court, which was denied. They subsequently sought leave to file a second motion for reconsideration, which was also denied. 3. The Petition: The petitioners are requesting leave to file a second motion for reconsideration of the Supreme Court's resolution denying their petition for certiorari. They argue that their claim over Lot 1873 is superior to Napocor's, citing a Bureau of Lands certification and asserting ownership through prescription. They also challenge the CA's finding that they did not raise issues concerning Lot 72. The Supreme Court, however, found that the Bureau of Lands certification was not proof of ownership, that their claim of prescription was inapplicable to public land, and that their prolonged inaction constituted laches, barring their claims for both lots.
Issue(s)
Whether the petitioners should be granted leave to file a second motion for reconsideration. Whether the petitioners sufficiently established their ownership over Lot 1873. Whether the petitioners acquired ownership over Lot 1873 through prescription under Article 1137 of the Civil Code. Whether the principle of laches bars the petitioners' claim over Lot 1873. Whether the petitioners have a valid claim over Lot 72.
Ruling
The Court DENIED the petitioners' motion for leave to file a second motion for reconsideration, declaring its Resolutions of January 18, 2010, and April 21, 2010, as final and executory. Double costs were assessed against the petitioners.
Ratio Decidendi
On the propriety of a second motion for reconsideration: The Court reiterated that a second motion for reconsideration is generally not entertained, and exceptions are granted only in the higher interest of justice by the Court en banc upon a vote of at least two-thirds of its members. The petitioners failed to substantially show that a reversal of the Court's ruling would serve the higher interest of justice, as their arguments were based on stale and unsubstantiated claims that would require abandoning settled principles of law. To accommodate such claims would be to accommodate legally baseless assertions, contrary to the interest of justice. On the sufficiency of proof of ownership over Lot 1873: The Court found that the Bureau of Lands certification stating Crispulo Ferrer was a survey claimant did not adequately establish ownership. A survey plan's purpose is to identify and delineate land, not to prove ownership. Furthermore, the OCTs in Emiliano Ferrer's name covered portions of Lot 1873 not occupied by Napocor's power plant. The Court also noted that Napocor presented duly notarized and registered deeds of sale for a significant portion of Lot 1873, which were not sufficiently refuted by the petitioners. On acquisition of ownership through prescription: The Court clarified that claims over alienable and disposable public lands are governed by Commonwealth Act No. 141 (Public Land Act), not by Article 1137 of the Civil Code, which applies only to private lands. Acquisition of alienable public lands requires open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier, and that the land be officially decreed as alienable and disposable. The petitioners failed to conclusively prove these requirements, as there was no definitive proof that Lot 1873 was declared alienable and disposable, nor was the nature and duration of their alleged possession established. On the application of the principle of laches: The Court found that the principle of laches barred the petitioners' claim over Lot 1873. From 1936, when Napocor occupied the lot and began construction, until 1997, when the suit was filed, the petitioners made no move to assert their claim. This 61-year period of inaction, despite Napocor's open acts contrary to their asserted ownership (purchase, construction, right of way grant), demonstrated a lack of vigilance and prejudiced Napocor, which had invested in the property and considered itself the owner. The law serves the vigilant, not those who sleep on their rights. On the claim over Lot 72: The Court agreed with the CA that the petitioners did not sufficiently raise issues concerning Lot 72 in their appeal, focusing instead on Lot 1873. Moreover, the RTC had already found that Napocor possessed a subsisting easement right of way over Lot 72, and that the lot had been adjudicated to Hilaria and Victoria Puhawan, rendering the petitioners' claim invalid as heirs of Engracia Puhawan.
Main Doctrine
A second motion for reconsideration is generally not allowed, and exceptions require a showing of higher interest of justice, which is not met by stale and unsubstantiated claims. Claims over alienable public lands are governed by Commonwealth Act No. 141, not by general Civil Code provisions on prescription, and require open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier. The principle of laches bars claims asserted after an unreasonable and unexplained delay, especially when it prejudices the adverse party.