G.R. No. 180476 ; June 26, 2013
Raymundo Coderias, represented by his Attorney-In-Fact, Marlon M. Coderias, Petitioner, vs. Estate of Juan Cidoco, represented by its Administrator, Dr. Raul R. Carag, Respondent.

FACTS

Petitioner Raymundo Coderias was the farmer-beneficiary of a 4-hectare farm in Nueva Ecija owned by the deceased Juan Chioco, having been issued a Certificate of Land Transfer in 1974. In 1980, individuals connected with Chioco forcibly evicted Coderias by threatening his life and bulldozing his house and standing crops. Fearing for his safety, Coderias and his family left the landholding. Upon learning of Chioco’s death in 1993, Coderias returned to the farm and re-established possession. In 1995, he filed a petition before the DARAB seeking restoration of possession, execution of a leasehold contract, and damages for the 1980 dispossession and lost harvests.
The Estate moved to dismiss, arguing prescription under Section 38 of RA 3844 (Agricultural Land Reform Code), which requires actions for reinstatement to be filed within three years from dispossession. The Provincial Agrarian Reform Adjudicator (PARAD) dismissed the petition on grounds of prescription and laches. The DARAB reversed, ordering Coderias’s reinstatement and payment for unrealized harvests. The Court of Appeals reinstated the PARAD’s dismissal, holding the action filed in 1995 was barred, having been commenced 14 years after the 1980 dispossession.

ISSUE

Whether the Court of Appeals erred in ruling that petitioner’s cause of action for reinstatement had prescribed.

RULING

The Supreme Court REVERSED the Court of Appeals and REINSTATED the DARAB Decision. The Court held that the three-year prescriptive period under Section 38 of RA 3844 did not bar the action. The legal logic is anchored on the principle that forcible dispossession of a tenant-farmer is a continuing tort. The prescriptive period does not run from the initial act of dispossession when the farmer’s exclusion is maintained through a continuing state of intimidation and force. Coderias’s dispossession in 1980 was not a single, completed act but was perpetuated by the looming threat from Chioco, a former governor. The coercive environment constituted a continuing wrong that ceased only upon Chioco’s death in 1993. Thus, the three-year period commenced only in 1993, making the 1995 filing timely.
The Court emphasized that agrarian reform laws are social legislation designed to protect farmers, and technical rules like prescription must yield to their beneficent intent. Allowing prescription to run while a farmer lives under threat would sanction the use of force and contravene the fundamental policy of securing tenant-farmers in their landholding. The delay in filing was justified and not indicative of abandonment, as the action was filed within three years from the cessation of the coercive acts.