Does a Certificate of Finality issued by the Lupon have an expiration or require a prescription?

In the Philippines, the Katarungang Pambarangay Law, as contained in the Local Government Code (Republic Act No. 7160), provides for the settlement of disputes at the barangay level through the Lupong Tagapamayapa. A Certificate of Finality is an important document issued by the Lupon to signify the finality of its decision in resolving disputes, including land disputes involving encroachment.

Understanding the Certificate of Finality

A Certificate of Finality is a formal document that indicates that a decision or award rendered by the Lupon has become final and executory. This means that no further appeals or motions for reconsideration can be entertained regarding the decision, and the parties are expected to comply with the terms of the resolution.

Prescription of Actions and Expiration of Certificates

No Expiration of the Certificate Itself: The Certificate of Finality issued by the Lupon does not have an expiration date. Once issued, it remains valid and enforceable indefinitely. However, the rights and obligations arising from the decision it certifies may be subject to prescription under general laws on prescription of actions.
Prescription of Enforcement Actions: While the certificate itself does not expire, the enforcement of the decision may be subject to the general rules on prescription of actions under the Civil Code of the Philippines. Typically, actions to enforce a right must be commenced within a certain period, often 10 years for actions based on a written contract or judgment (Article 1144 of the Civil Code).
Effect of Prescription: If a party does not take action to enforce the decision within the prescriptive period, they may lose the right to enforce it. This means that while the Certificate of Finality remains valid, the ability to enforce the decision it certifies may be barred by prescription.

Legal Basis and Implications

The absence of an expiration date for the Certificate of Finality aligns with the principle that final and executory decisions remain binding unless challenged or nullified by competent authority. However, the enforceability of such decisions is subject to the rules on prescription of actions, ensuring that rights are asserted and enforced within reasonable time limits to avoid undue delay and uncertainty in legal relations.

Practical Considerations

Timely Enforcement: Parties in land disputes resolved by the Lupon should take prompt action to enforce the decision to avoid the bar of prescription.
Legal Advice: It is advisable to seek legal counsel to understand the specific prescriptive periods applicable to the enforcement of the Lupon's decisions and to ensure that all procedural requirements are met.

Conclusion

In summary, while the Certificate of Finality issued by the Lupon does not expire, the actions to enforce the decision it certifies must be taken within the applicable prescriptive period under Philippine law. This ensures that parties act promptly to uphold their rights and maintain the finality and integrity of the Lupon's resolutions.