Title
Buisan vs. Commission on Audit
Case
G.R. No. 212376
Decision Date
Jan 31, 2017
DPWH flood control project in 1989 led to landowners’ claims for damages. COA denied claims due to laches, prescription, and procedural non-compliance; SC upheld decision, citing state immunity and lack of evidence.
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Case Digest (G.R. No. 212376)

Facts:

Background of the Case

In 1989, the Department of Public Works and Highways (DPWH) undertook the construction of the Liguasan Cut-off Channel in Tunggol, Pagalungan, Maguindanao, to address perennial flooding in the area. In April 2001, the DPWH received claims from landowners alleging that the premature opening of the project caused damage to their properties, crops, and improvements.

Investigation and Recommendations

The DPWH Regional Office No. XII and a Technical Working Group (TWG) investigated the claims. In 2004, the TWG recommended payment of just compensation but noted that due to the lapse of time since 1989, it was impossible to physically verify the extent of the damage. An ad hoc committee was formed in 2006 to assess the legality of the claims, but no resolution was reached due to insufficient evidence. The claims were forwarded to the Commission on Audit (COA) for adjudication.

Filing of the Petition

On April 14, 2010, the petitioners, represented by Mayor Bai Annie C. Montawal, filed a petition with the COA seeking P122,051,850.00 as compensation for damages. However, some petitioners contested Montawal’s authority to represent them and filed a separate petition.

DPWH’s Defense

The DPWH argued that the petitioners failed to prove ownership of the damaged properties or that the damage was caused by the project. It also asserted that the petitioners’ cause of action had prescribed.

COA’s Decision

On November 20, 2012, the COA denied the petitioners’ money claims, citing laches and prescription under Article 1146 of the Civil Code. The petitioners’ motion for reconsideration was also denied.

Issue:

  1. Whether the COA gravely abused its discretion in finding that the petitioners’ claim was barred by laches and prescription.
  2. Whether the petitioners complied with the procedural requirements, particularly the certification against forum shopping.
  3. Whether the Doctrine of Non-Suability of the State applies to insulate the DPWH from liability.
  4. Whether the petitioners’ cause of action had prescribed and was barred by laches.

Ruling:

The Supreme Court denied the petition, affirming the COA’s decision. The Court held that:

  1. The petitioners failed to comply with the certification against forum shopping requirement, as the certification was signed by Mayor Montawal, who lacked proper authority to represent the petitioners.
  2. The Doctrine of Non-Suability of the State applies, as the DPWH was performing a governmental function in constructing the flood control project. The State did not consent to be sued.
  3. The petitioners’ cause of action had prescribed under Article 1146 of the Civil Code, which requires actions for injury to rights or quasi-delicts to be filed within four years. The claims were filed 15 years after the alleged damage occurred.
  4. Laches also barred the claims, as the petitioners unreasonably delayed in asserting their rights, prejudicing the DPWH’s ability to defend itself.

Ratio:

  1. Procedural Compliance: The certification against forum shopping must be signed by the petitioners themselves or their authorized counsel. Mayor Montawal’s certification was insufficient, as she lacked proper authority to represent the petitioners.
  2. Doctrine of Non-Suability: The State cannot be sued without its consent. The DPWH, as a government agency performing a governmental function, is immune from suit unless the State consents.
  3. Prescription and Laches: The petitioners’ claims were filed beyond the four-year prescriptive period under Article 1146 of the Civil Code. Additionally, the unreasonable delay in filing the claims constituted laches, which bars recovery.
  4. COA’s Discretion: The COA did not gravely abuse its discretion in denying the claims. Its findings were supported by evidence, including inconsistencies in the petitioners’ claims and the lack of substantial proof of damage caused by the DPWH’s project.

Conclusion:

The Supreme Court dismissed the petition, upholding the COA’s denial of the petitioners’ money claims. The Court emphasized the importance of procedural compliance, the State’s immunity from suit, and the principles of prescription and laches in barring stale claims.


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