Marcopper Mining Corp. v. Calancan Bay Fisherfolk Federation

Summary

Marcopper Mining Corp. challenged the denial of its motion to dismiss a class suit filed by Calancan Bay fisherfolk, claiming the quasi-delict action had prescribed under Civil Code Article 1146. The Supreme Court affirmed the Court of Appeals' dismissal of the certiorari petition, ruling that the RTC properly denied the motion to dismiss since the actual reckoning point for prescription could not be determined from the pleadings alone. The Court emphasized that factual issues regarding prescription and causation must be resolved through full trial, as the damage and causation could not have been reasonably determined earlier than the filing date. The decision highlights the principle that prescription periods begin when the right of action accrues, which occurs when all facts constituting the cause of action have occurred and can be reasonably determined.