Case Summary (G.R. No. 212376)

Background of the Case

• The case involves a petition for review on certiorari filed by Madag Buisan and others against the Commission on Audit (COA) and the Department of Public Works and Highways (DPWH).
• The petitioners sought compensation amounting to P122,051,850.00 for damages to their properties allegedly caused by the premature opening of the Liguasan Cut-off Channel Project in 1989.
• The COA denied the claims on November 20, 2012, citing lack of merit and the expiration of the petitioners' cause of action due to laches and prescription.

Procedural History

• The DPWH initiated the construction of the Liguasan Cut-off Channel in 1989 to address flooding issues in the area.
• In 2001, landowners, including the petitioners, filed claims for damages due to the project.
• An investigation by the DPWH led to recommendations for compensation, but no final resolution was reached due to insufficient evidence and the passage of time.
• The petitioners filed a petition with the COA in 2010, which was met with a motion to dismiss from the DPWH, arguing that the petitioners failed to prove ownership of the damaged properties and that their claims had already prescribed.

COA's Findings

• The COA found that the petitioners did not file their claims within a reasonable time, leading to a presumption of laches.
• The COA also determined that the petitioners' cause of action had prescribed under Article 1146 of the Civil Code, which mandates a four-year period for filing claims related to injuries to rights or quasi-delicts.

Legal Issues Raised

• The primary issue was whether the COA gravely abused its discretion in concluding that the petitioners' claims were barred by laches and prescription.
• The petitioners contended that their claims were valid and should not have been dismissed.

Court's Ruling on Procedural Compliance

• The Court dismissed the petition due to the petitioners' failure to comply with the certification against forum shopping requirement.
• The certification was signed by Mayor Bai Annie C. Montawal, who lacked proper authority to represent the petitioners, as evidenced by the motion to dismiss filed against her.

Doctrine of Non-Suability of the State

• The Court reiterated the principle that the State cannot be sued without its consent, which applies to the DPWH as a governmental entity.
• The DPWH's actions in constructing the project were deemed to be within its governmental functions, thus insulating it from liability for damages.

Prescription and Laches

• The Court upheld the COA's finding that the petitioners' claims were barred by prescription and laches due to the significant delay in filing their claims.
• The petitioners' assertion that their cause of action arose in 1992 was unsupported by evidence, and the claims were filed 15 years after the alleged damages occurred.

COA's Jurisdiction and Authority

• The Court confirmed that the COA has primary jurisdiction over money claims against government agencies, as established by Commonwealth Act No. 327 and subsequent laws.
• The COA's role includes safeguarding the proper use of government funds and ensuring that claims against the g...continue reading

Case Syllabus (G.R. No. 212376)

Case Overview

• The case concerns a Petition for Review on Certiorari (G.R. No. 212376) filed by Madag Buisan and others against the Commission on Audit (COA) and the Department of Public Works and Highways (DPWH).
• The petition challenges COA's Decision dated November 20, 2012, which denied claims for damages amounting to P122,051,850.00 due to alleged property damage caused by the DPWH's project.

Antecedents

• In 1989, DPWH initiated the construction of the Liguasan Cut-off Channel in Tunggol, Pagalungan, Maguindanao, intended to alleviate flooding issues.
• By April 2001, landowners began claiming damages due to the project's premature opening.
• An investigation was conducted by the DPWH, which led to recommendations for compensation; however, by 2006, no resolution was reached due to insufficient evidence.
• On April 14, 2010, petitioners, represented by Mayor Bai Annie C. Montawal, formally filed a claim with COA for compensation.
• The DPWH contested the claim, arguing lack of proof of ownership and cause of damage, and asserted the claims had already prescribed.

COA's Decision

• The COA denied the money claims on November 20, 2012, citing lack of merit, asserting that the claims were barred by laches and prescription, specifically referring to Article 1146 of the Civil Code.
• The petitioners filed a motion for reconsideration, which was subsequently denied.

Legal Issues

• The primary issue addressed was whether ...continue reading