Case Summary (G.R. No. 175343)
Factual Background
The heirs of Daniel T. Tirona sought compensation for two lots totaling 12,045 square meters, which were occupied by the National Government as part of the national highway from Noveleta to Cavite City. These lots, covered by Transfer Certificates of Title No. 1709 and No. 442, were originally registered under Daniel T. Tirona prior to his death in 1939. The heirs maintained current Tax Declarations for the lots and had continued paying real estate taxes, despite the absence of any formal conveyance of the property to the government.
Procedural History
In 1952, the heirs approached the District Engineer regarding compensation for the land occupied by the highway. Although there were negotiations regarding a right of way agreement, no consensus on terms was achieved. The claim was subsequently submitted to the Auditor General in 1960, but it was rejected on the grounds of presumed prior consent for the government's use of the land and the assertion of prescription due to the passage of time without compensation.
Legal Analysis
The Supreme Court found that the Auditor General's rejection of the heirs' claim lacked legal foundation. The presumption of regularity in government actions did not apply since the ownership of the land was established under the Torrens system, which requires formal documentation for any conveyance. The absence of a recorded deed of conveyance, whether through sale or donation, substantiated the petitioners' position that the land remained theirs. The Court emphasized that without proper recording, no alteration of title could be legally acknowledged under the Torrens system.
Exception to Prescription
The Court acknowledged that while the prescriptive period would typically bar recovery for claims not pursued within the designated timeframe, an exception exists for cases where the government has taken private property without providing compensation. Citing previous cases (Herrera vs. Auditor General and Alfonso vs. Pasay City), the Court reaffirmed that equity demands that the government must compensate property owners for any expropriation regardless of the timeliness of the claim, particularly when dealing with registered land.
Conclusion and Decision
The Court reject
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Case Citation
- G.R. No. L-22403
- Decision Date: October 31, 1968
- Philippine Reports Citation: 134 Phil. 883
Parties Involved
- Petitioners: Luis, Buenaventura, Antonio, and Daniel Castro, heirs of the late Daniel T. Tirona of Dalahican, Cavite.
- Respondent: The Auditor General of the Republic of the Philippines.
Background of the Case
- The petitioners sought compensation for two lots, specifically Lot No. 5 of Transfer Certificate of Title No. 1709 and Lot No. 6 of Transfer Certificate of Title No. 442.
- The total area of the lots in question amounts to 12,045 square meters, currently occupied by the National Government as part of the national highway from Noveleta to Cavite City.
- The construction of the aforementioned road dates back to 1917, at which time the land was covered by Original Certificates of Title Nos. 168, 48, and 443, issued in 1916 in the name of Daniel T. Tirona, who passed away in 1939.
Key Facts
- There is no recorded annotation in favor of the government on the original certificates of title.
- Both lots are assessed at P570.00 and P3,290.00 respectively and are covered by tax declarations in the name of the heirs, who have consistently paid real estate taxes on these properties.
- No deed of conveyance for the lots to the government has been executed by the registered owner or his heirs.
Claims and Proceedings
- In 1952, the heirs filed a complaint with the District Engineer, Miguel Tana, regarding non-payment for the la