Facts:

The case involves Estanislao Alfonso as the plaintiff and appellant against Pasay City, the defendant and appellee. The matter was brought before the Supreme Court of the Philippines, with the decision issued on January 30, 1960. The origin of the dispute traces back to 1925 when the Municipality of Pasay extended Park Avenue southward, encroaching upon Lot No. 4368, which had an area of 719.92 square meters and was owned by Alfonso, registered under Transfer Certificate of Title No. 1057 (30999). This extension effectively converted the lot into part of a public park avenue, but no expropriation proceedings took place, nor was Alfonso compensated for the land taken from him.

For nearly three decades, beginning in 1925, the lot was in continuous use as part of the extension of Park Avenue. Alfonso contended that despite his rightful ownership, the municipality failed to acknowledge his property rights, leading to a total utility of the land by Pasay City without any payment. By

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Facts:

Background of the Case

• Estanislao Alfonso, the registered owner of Lot No. 4368 (area: 719.92 sq. meters), held title under Transfer Certificate of Title No. 1057 (30999).
• In 1925, the then Municipality of Pasay extended Park Avenue southward, with the extension passing through Lot No. 4368.
• The lot was thereby converted into part of the public street (a park area) used for the roadway without any expropriation proceedings or payment of compensation to Alfonso.

Facts as Stipulated by the Parties

• The parties agreed on the undisputed facts through a stipulation of facts submitted to the trial court.
• Alfonso’s land has been continuously used as part of the Park Avenue extension from 1925 until the filing of the action in 1954.
• Despite any possible demands made by Alfonso for compensation or restoration of possession, the local government (now Pasay City) failed to either purchase or return the land.

Legal and Factual Context

• Alfonso filed the present action on July 20, 1954, seeking recovery either of the land’s possession or its monetary value.
• The case was initially dismissed on the ground of laches and prescription by the Court of First Instance of Rizal (Pasay City Branch) on November 26, 1958.
• The factual scenario echoes that of Herrera vs. Auditor General, where a landowner in Quezon City was similarly deprived of possession for road purposes without due compensation.
• It is emphasized that as a registered owner, Alfonso’s rights cannot be extinguished by prescription, even though the possession may have been effectively transferred to public use over decades.

Governmental Conduct and Practical Considerations

• The case highlights the government's practice of appropriating private registered property for public use without proper expropriation procedures or a negotiated sale.
• There is a strong indication that government delays, red tape, and changes in administration contributed to failing to settle rightful claims for compensation.
• The Court noted the inherent inequity, as a private landowner is at a disadvantage when facing a government that occupies his property without reaching a fair compensation agreement.

Valuation and Calculation of Damages

• The stipulated facts fixed the value of the land at P1.25 per square meter at the time of appropriation (1925).
• For the entire area of 719.92 square meters, the base compensation is computed by multiplying the area by P1.25.
• Additionally, the damages for the government’s failure to pay rent or compensation since 1925 may be assessed in the form of legal interest.
• The Court also fixed attorney’s fees in favor of Alfonso at the amount of P400.00.

Issue:

Whether the doctrine of prescription (and laches) may bar the recovery of compensation for a registered property taken for public use.

• The defense raised that the long lapse of time should prevent Alfonso from claiming compensation.
• The issue challenges the application of prescription rules to registered land used by the government for road purposes.

Whether the government, by appropriating a registered private property for public benefit without following formal expropriation proceedings or a negotiated sale, is constitutionally or legally obliged to pay just compensation.

• The inquiry centers on the constitutional mandate to provide just compensation when private property is taken for public use.
• It also considers the equity principle that discourages government misconduct in handling private property rights.

The appropriate measure of compensation for a property appropriated in 1925, including the effect of accrued legal interest on the base value.

• The issue involves determining whether the value should be based on the market value at the time of the action or the assessed value at the time of appropriation.
• The calculation of damages also prompts the assessment of interest from 1925 until the date of eventual payment.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)