G.R. No. 91787 - Terminal Facilities and Services Corp. vs. National Labor Relations Commission

Petitioners: Luis, Buenaventura, Antonio, and Daniel Castro, who are the heirs of the late Daniel T. Tirona of Dalahican, Cavite.
Respondent: The Auditor General of the Republic of the Philippines.
Property in Issue: Two lots—Lot No. 5 (from Transfer Certificate of Title No. 1709) and Lot No. 6 (from Transfer Certificate of Title No. 442) totaling 12,045 square meters.
Location and Usage: The lots form part of the national highway from Noveleta to Cavite City, a road constructed as far back as 1917.

Original Titles: The lots were originally part of larger land areas covered by Certificates Nos. 168, 48, and 443.
Registration Date: The land was registered under the Torrens system in 1916 in the name of Daniel T. Tirona.
Absence of Conveyance Annotation: There is no annotation on the original certificates or recorded conveyance indicating that the property was transferred to the Government.
Tax Declarations: The lots are covered by corresponding Tax Declarations in the name of Tirona's heirs, who have also paid the real estate taxes up to the present.

Initial Claim: Sometime in 1952, the heirs complained to the District Engineer, Miguel Tana, regarding non-payment for the lots occupied by the national road.
Negotiation Attempts: Negotiations for a right-of-way agreement were made; however, no agreeable terms were reached between the parties.
Submission to Auditor General: In 1960, the claim for compensation was formally submitted to the Auditor General.

Presumption of Regularity: It was presumed that the original owner had given consent and had been paid, following the regular course of business.
Prescription: The claim was deemed time-barred, given that no payment was made within the applicable period.

Torrens System and Deed Recording: Under the Torrens system, any conveyance affecting registered lands must be recorded in the Register of Deeds and noted on the Certificate of Title; no such record exists in this case.
Government Practice: Evidence suggests that if the property had been conveyed by sale or as a donation, proper records or public documents should have been executed and recorded, which did not occur.
Precedent Cases: Similar situations were noted in Herrera vs. Auditor General and Alfonso vs. Pasay City, where the government had taken possession of private registered lands without payment.

Whether the presumption of regularity, which suggests that a conveyance was validly executed if in the regular course of business, applies given that no recorded or annotated deed exists.

The issue arises because the Torrens system mandates proper recording and annotation to effect a conveyance.
The absence of such recordings negates the assumption that the property was transferred to the Government.

Whether the claim for compensation is barred by the lapse of the prescriptive period.

The Auditor General argued that the claim had prescribed due to the passage of time.
The counter-issue is whether an exception to prescription applies when the Government has taken private registered land without compensating the owner.

Whether equity and justice demand that the Government indemnify private landowners for the taking of their property, irrespective of the lapse of time.

Prior jurisprudence (Herrera and Alfonso cases) suggests an exception applies when the Government appropriates private property.
The central issue is determining if the government’s conduct warrants compensation notwithstanding the potential prescription.