Delfin v. National Housing Authority
REITERATIONFacts
The Antecedents: The Delfin Spouses claimed ownership of a 28,800 square meter property in Iligan City, which they allegedly bought in 1951 from individuals in possession since time immemorial. They declared the property for tax purposes since 1952 and cultivated it. In 1982, the National Housing Authority (NHA) took possession of a 10,798 square meter portion without compensation. The Delfin Spouses filed a complaint for payment of the property's value and damages. Procedural History: The Regional Trial Court (RTC) ruled in favor of the Delfin Spouses, awarding compensation for the land and improvements, plus attorney's fees. The NHA appealed. The Court of Appeals (CA) reversed the RTC decision, dismissing the complaint and declaring the property as public domain. The CA denied the Delfin Spouses' motion for reconsideration. The surviving heirs of the Delfin Spouses (petitioners) elevated the case to the Supreme Court. The Petition: Petitioners sought the reversal of the CA decision and the reinstatement of the RTC decision, arguing that they and their predecessors-in-interest had open, continuous, exclusive, and notorious possession for over 30 years, converting the property to private land through acquisitive prescription under PD 1529, and that government agency certifications supported their claim of possession since June 12, 1945.
Issue(s)
Whether petitioners are entitled to just compensation for the property occupied by the National Housing Authority. Whether petitioners acquired ownership of the property through acquisitive prescription under Section 14(2) of Presidential Decree No. 1529. Whether petitioners acquired title to the property under Section 48(b) of Commonwealth Act No. 141 (Public Land Act).
Ruling
The Petition is GRANTED. The assailed Court of Appeals Decision dated February 26, 2010 and Resolution dated July 2, 2010 in CA-G.R. CV No. 80017 are REVERSED and SET ASIDE. The Regional Trial Court's Decision dated May 20, 2002 in Civil Case No. II-1801 is REINSTATED.
Ratio Decidendi
On the issue of just compensation: The Court's ruling on acquisitive prescription and title under the Public Land Act directly impacts the entitlement to just compensation. If the petitioners successfully demonstrate ownership, they are entitled to just compensation. The determination of ownership is thus a prerequisite to the issue of just compensation. On the issue of acquisitive prescription under Section 14(2) of Presidential Decree No. 1529: The Court held that for acquisitive prescription to set in under Section 14(2) of PD 1529, two requirements must be satisfied: first, the property must be established to be private in character, and second, the applicable prescriptive period must have passed. Property is either of public dominion or private ownership. Land of the public domain, to be susceptible to prescription, must be patrimonial in character. Article 1113 of the Civil Code explicitly states that property of the State not patrimonial in character is not an object of prescription. For land of the public domain to be converted into patrimonial property, there must be an express declaration by the State, in the form of a law or Presidential Proclamation, that the property is no longer intended for public service or development of national wealth. A mere indorsement from the Executive Secretary is insufficient to effect this conversion. Therefore, regardless of the length of possession, no title could vest on petitioners by way of prescription under PD 1529 because the property was not patrimonial at the onset. On the issue of title under Section 48(b) of Commonwealth Act No. 141 (Public Land Act): The Court found that petitioners could claim title under Section 48(b) of the Public Land Act. This section allows for the confirmation of claims and issuance of titles to citizens occupying or claiming ownership of alienable and disposable agricultural lands of the public domain under a bona fide claim of acquisition or ownership since June 12, 1945. The requirements are: (1) the land must be agricultural, and (2) there must be open, continuous, exclusive, and notorious possession and occupation since June 12, 1945. The Court noted that the NHA conceded the property was alienable and disposable. While the Delfin Spouses' direct evidence of possession only went back to 1952, documentary evidence, specifically letters from a Deputy Public Land Inspector, attested to the property being occupied as early as June 1945 and having been released for agricultural purposes in favor of its occupants. This evidence satisfied the requisites of Section 48(b) of the Public Land Act, entitling petitioners to compensation for the taking of their property.
Main Doctrine
For acquisitive prescription under Section 14(2) of Presidential Decree No. 1529 to set in, the property must be private in character at the onset, or there must be an express declaration by the State that public dominion property is no longer intended for public service or development of national wealth. Possession alone does not convert public land into patrimonial property. However, title may be acquired under Section 48(b) of Commonwealth Act No. 141 if the land is agricultural, alienable, and disposable, and there has been open, continuous, exclusive, and notorious possession and occupation since June 12, 1945.