Facts:

The case involves a petition for review on certiorari filed by Eufemia Abad and the spouses Flordeliza Abad-Cezar and Pollie Cezar (petitioners) against the heirs of Jose Eusebio Abad Gallardo, namely Dolores Lolita J. Gallardo, Jocelyn A. Gallardo, Judith A. Gallardo, and Jonah Gallardo (respondents). The petition was filed on November 10, 2020, and it challenges the Resolutions dated September 27, 2016, and December 9, 2016, of the Regional Trial Court (RTC) of Santiago City, Branch 36, in Civil Case No. 36-4014. The case centers around a parcel of land, Lot 5826-B, consisting of 5,000 square meters located in Capiddigan, Cordon, Isabela, which is part of a larger property originally covered by Original Certificate of Title No. P-2769, registered in the names of Spouses Miguel Abad and Agueda de Leon. After the death of the spouses, the land was inherited by their three children, including Enrique Abad, who later became the registered owner of the property under Transfer Ce...

Facts:

Parties and Subject Matter

• Petitioners:
• Eufemia Abad;
• Spouses Flordeliza Abad-Cezar and Pollie Cezar – all heirs of Enrique Abad.
• Respondents:
• Heirs of Jose Eusebio Abad Gallardo, namely:
• Dolores Lolita J. Gallardo;

ii. Jocelyn Gallardo; iii. Judith Gallardo; and iv. Jonah Gallardo.

Historical Background and Chain of Title

• Inheritance and Registration:
• Originally issued to Spouses Miguel Abad and Agueda de Leon;
• Upon their death, the land was inherited by their three children: Dionisio, Isabel, and Enrique;
• Enrique’s name appeared on TCT T-131684 after the cancellation of OCT P-2769.
• Early Litigation and Settlement:
• Civil Case No. 0591 (filed January 15, 1988, at RTC Branch 21, Santiago City) involved the annulment of a deed and the title issue regarding TCT T-131684, with Dionisio and Isabel challenging Enrique’s claim based on an alleged extrajudicial settlement and waiver of rights.
• Proceedings included:
• Enrique’s failure to timely answer and an initial presumption of a compromise agreement;

ii. A dismissal on December 27, 1988, later reinstated on February 3, 1989; iii. A final dismissal on August 25, 1989 after a deed of partition was notarized, dividing the land among the three siblings.

Subsequent Conveyances and Transactions

• Transfer by Donation:
• On July 4, 2004, following Isabel’s death, Lot 5826-B was donated to her son, Jose Eusebio Abad Gallardo, through a deed of donation.
• Financial Transaction and Collateral:
• On April 30, 2008, the subject lot was involved in a transaction where:
• Furtunato Abad, the tenant, relinquished tenancy in exchange for P50,000.00;

ii. Dolores Lolita Gallardo (then widowed) secured a P75,000.00 loan from Eufemia Abad using the lot as collateral, evidenced by a Kasunduan.

Procedural History in the Instant Case

• Initiation of Suit:
• Respondents filed a complaint for specific performance, surrender of title, redemption, and consignation with damages.
• Their allegations focused on:
• The existence of a partition agreement and an approved subdivision plan;

ii. Documented transactions including an amicable settlement, deed of partition, and deed of donation.

Issue:

Appropriateness of Granting Judgment on the Pleadings

• Whether the RTC was correct in granting judgment on the pleadings in favor of the respondents given that petitioners’ answer failed to raise specific issues on certain allegations.

Applicability of Res Judicata

• Whether res judicata applies in the instant case based on the prior proceedings in Civil Case No. 0591, considering:
• The alleged existence but non-approval of a compromise agreement;
• The absence of a judgment on the merits in the earlier action;
• The lack of identity of causes of action between the prior and present cases.

Sufficiency of Specific Denials Regarding Document Authenticity

• Whether petitioners’ failure to deny under oath the genuineness of certain documents (e.g., the amicable settlement, deed of partition, kasunduan) constitutes an admission under the Rules of Civil Procedure.

Need for a Trial on the Merits Versus Relying on Technicalities

• Whether hastily concluding judgment on the pleadings would prejudice the full adjudication of the dispute’s factual controversies, particularly on issues of title, possession, and collateral agreements.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)