Short answer. Yes, if you were constrained to pay. Article 2175 provides that any person who is constrained to pay the taxes of another shall be entitled to reimbursement from the latter. The right runs against the person whose tax it was, and it turns on the word constrained.
What the law says
Any person who is constrained to pay the taxes of another shall be entitled to reimbursement from the latter.
Civil Code, Article 2175 — Paying Another's Taxes. Read the full provision →
Constrained, not merely willing
The article is not a licence to pay other people's obligations and send them a bill. It speaks of a person constrained to pay, which points at payment made under compulsion rather than as a favour or a gamble. Being told your own transaction cannot proceed until the arrears are settled, or paying to head off a sale or a lien that would strike your own interest, is the shape the provision has in mind. Paying voluntarily in the hope of being thanked afterwards is a different situation and a much weaker claim.
Whose tax was it?
The reimbursement runs against the latter, the person whose taxes they were, so the claim is only as good as your identification of that person. On real property that is a question about who owned or was liable for the property in the years the assessment covers, which is not always whoever is now in possession or named on an old declaration. Get the tax declaration, the assessment and the receipts, and match each year to the owner of record for it. A demand sent to the wrong person achieves nothing and warns the right one.
What the article does not give you
It gives you a claim for money against a person. It does not give you any right in the land itself — no title, no lien, no priority over anyone else with a claim against him. Paying the tax on property does not make the property yours, and years of paying does not ripen into ownership on its own. If your real concern is the land rather than the money, that is a different question with different requirements, and it should be put to a lawyer as that question rather than as this one.
Keep the documents that show both halves
That the tax was another's, and that you were constrained. Official receipts in your own name, the assessment or statement of delinquency, the tax declaration showing the property and the years covered, and the notice or correspondence that forced your hand. A written demand for reimbursement, dated and sent so that receipt can be proved, is worth making promptly rather than eventually. A claim for money also runs against a prescriptive period, so do not let it sit for years while you decide.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Myrna Ramos vs. Susana S. Sarao, et al, G.R. No. 149756, February 11, 2005 — read the decision on LawPhil →