Short answer. Never. Movables possessed through a crime can never be acquired through prescription by the offender, however many years pass. There is no waiting period that cures the taking. The bar is personal to him, though — it is not by itself the answer to what happens once the thing has passed to someone else.
What the law says
Movables possessed through a crime can never be acquired through prescription by the offender.
Civil Code, Article 1133 — Stolen Movables Never Prescribe for the Thief. Read the full provision →
One sentence, no exceptions
Prescription normally rewards long undisturbed possession, and for movables the periods are short — Art. 1132 turns four years of good-faith possession, or eight years without any other condition, into ownership. This article removes the offender from that scheme altogether. Movables possessed through a crime can never be acquired through prescription by the offender. There is no period, however long, at the end of which the person who took the thing owns it. The Code refuses to let time launder a crime into a title.
Wider than theft
The phrase is possessed through a crime, not "stolen", and that is deliberate. It reaches the property in the hands of the robber, but equally the goods obtained by swindling, the funds an officer misappropriated, the vehicle taken by carnapping. What links them is that the offender's very possession originated in the offence. Note also what the article does not require: no conviction is written into it as a condition, and the provision speaks of movables — the enduring bar for immovables lives in the requirement that prescriptive possession be adverse and in the protection given to registered land.
The bar is personal to the offender
Read the last two words. The article disqualifies the offender, and it does not by its own terms decide the position of a later holder who bought the thing without knowing where it came from. That is governed by other rules, including those on sales by a person who is not the owner, and it is where most real disputes about stolen goods actually sit — not between owner and thief, but between owner and the third person now holding the car or the ring. Do not read this article as saying that everyone downstream is equally barred.
The owner still has a clock of his own
The thief's disability is not the owner's licence to wait. Art. 1140 gives eight years to bring an action to recover a movable, counted from the time possession was lost rather than from the day you learn where the thing is. So the practical answer to "he can never own it" is: true, and you can still be too late to get it back. Fix the date of the loss with a police report, keep the serial numbers, engine number, receipts and photographs, and act as soon as the property surfaces.
Related provisions
- Civil Code, Article 1133 — Stolen Movables Never Prescribe for the Thief
- Civil Code, Article 1132 — Prescription of Movables
- Civil Code, Article 1140 — Recovery of Movables — 8 Years