- Petitioner
- Madag Buisan
- Respondent
- Commission On Audit
- Citation
- G.R. No. 212376
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Reyes, J.
- Decided
- January 31, 2017
Summary
Petitioners sought P122,051,850.00 from DPWH for alleged crop and property damages from 1989 Liguasan Cut-off Channel project. COA denied claims citing 15-year delay constituting laches and prescription under Civil Code Article 1146. Supreme Court dismissed certiorari petition, finding procedural defects in forum shopping certification and applying state immunity doctrine protecting DPWH's governmental functions. Court upheld COA's findings of insufficient evidence, noting inconsistencies in damage claims, questionable ownership documentation, and conflicting lot assessments. Decision emphasized administrative agencies' specialized expertise and presumption of validity absent grave abuse of discretion, reinforcing proper procedural compliance and timely assertion of claims against government entities.
Intellegal Wiki · Key Holding
Dismissed the petition and affirmed the COA; the forum-shopping certification was fatally defective, the DPWH enjoys state immunity for governmental functions, and the money claim was barred by prescription and laches.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.