G.R. No. 51513 - People vs. Gorospe

The dispute arose from a complaint filed on February 2, 1996, by the respondents, Spouses Jose C. Campos, Jr. and Ma. Clara A. Lopez-Campos, who are the owners of a parcel of land in Bo. San Agustin, Dasmariñas, Cavite, covered by Transfer Certificate of Title No. T-957323.
The controversy began when, in the mid-1970s, Dr. Paulo C. Campos—a relative of respondent Jose C. Campos, Jr. and then-President of the Cavite Electric Cooperative—requested that the respondents temporarily allow the petitioner, National Power Corporation (NPC), to install wooden electrical posts and transmission lines on a portion of their property to facilitate the electrification of Puerto Azul.
The respondents granted permission on the condition that the installation was temporary and that the wooden posts would eventually be removed when permanent facilities were installed.
Contrary to the agreement, NPC continued using the property without relocating the temporary installations or compensating the respondents.

In 1994, NPC’s agents allegedly trespassed onto the subject property to conduct engineering surveys, leading the respondents’ caretaker to ask them to vacate the premises.
In 1995, another incident occurred when an agent claiming to represent NPC sought permission—through an unofficial letter purportedly from Justice Jose C. Campos, Jr.—to enter the property for a survey related to the erection of an all-steel transmission line tower on 24 square meters within the property. When the caretaker requested verification, the NPC agents refused and consequently were ordered to leave.
Later that year, on December 12, 1995, NPC initiated expropriation proceedings (Civil Case No. 1174-95) in the RTC of Imus, Cavite, seeking to acquire a portion of the property for a right-of-way. NPC asserted that the chosen site was “compatible with the greatest public good and the least private injury,” and claimed that negotiations for a right-of-way easement had been attempted, despite the respondents’ denial of any such negotiations.
The respondents contended that NPC’s choice of the subject property was arbitrary and capricious, especially given the availability of other less injurious sites, and argued that the unauthorized and prolonged use of their property prejudiced the value and marketability of the land, notably affecting its sale to Solar Resources, Inc.

Upon receipt of the complaint and summons, NPC did not file a responsive pleading but instead moved to dismiss the suit on grounds of prescription and litis pendency, contending that another pending action existed for the same cause.
The RTC denied the motion to dismiss on May 2, 1996, and later declared NPC in default for failing to file an answer after its motion for reconsideration was likewise denied.
NPC subsequently filed a petition for certiorari, prohibition, and preliminary injunction with the Court of Appeals (CA) against the orders of the RTC, but the petition was dismissed on February 13, 1996.
On September 26, 1996, the RTC rendered a decision ordering NPC to pay the respondents actual, moral, and nominal damages, along with attorney’s fees and costs.
The decision was appealed by NPC, and on June 16, 2000, the CA affirmed in toto the RTC ruling, upholding the award of damages and rejecting NPC’s contentions regarding prescription and litis pendency.

NPC contended that it had acquired an easement of right-of-way by prescription under Article 620 of the Civil Code, claiming its unchallenged use of the property from the mid-1970s to the early 1990s amounted to adverse possession.
The petitioner also invoked Section 3(i) of its Charter (Republic Act No. 6395, as amended) alleging that because the respondents had not acted within the prescribed five-year period after the establishment of the right-of-way, their claims for damages had prescribed.
NPC argued that the respondents’ failure to timely file their claims, coupled with what it considered a mischaracterization of the facts (i.e., asserting that negotiations had occurred), barred their recovery.

The trial record detailed that the respondents had never been notified of any plan to move the wooden posts or convert the temporary installation into a permanent facility.
Evidence indicated that NPC’s agents repeatedly trespassed onto the property without proper authority, and one such instance involved presenting an unverifiable letter of authority purportedly from Justice Jose C. Campos, Jr.
The misconduct by NPC—including improper entry, failure to honor the temporary nature of its use, and alleged misrepresentations regarding negotiations—was found to have substantially harmed the respondents both economically and reputationally.

Whether NPC’s long-standing use of the respondents’ property constituted sufficient and adverse possession to acquire an easement of right-of-way by prescription under Article 620 of the Civil Code.
Whether the mere tolerance of the respondents, which allowed NPC to install wooden posts and transmission lines, could legally generate a prescriptive right.

Whether Section 3(i) of the NPC Charter could be invoked to bar the respondents’ claims for compensation and damages due to the lapse of time following the establishment of the right-of-way.
Whether the requirements for invoking this provision, particularly the payment of just compensation and proper acquisition of title through valid processes, were satisfied by NPC.

Whether the findings and award of actual, nominal, and moral damages, as well as attorney’s fees and costs, by the RTC—and subsequently affirmed by the CA—were justified given NPC’s acts of trespass and misrepresentation.
Whether the misconduct of NPC, including the alleged deception involving a letter of authority, sufficiently constituted grounds for the awards granted by the lower courts.