Facts:

In the case of Fabian B. S. Abellera vs. Narciso De Guzman et al., decided on March 14, 1950, by the Supreme Court of the Philippines, the events trace back to March 22, 1918, when a lower court dismissed Abellera's ejectment complaint against nineteen individuals, whom he accused of being trespassers or squatters on a tract of land he claimed to own. The basis of the dismissal was Abellera's failure to establish a valid title to the hacienda in question, which he claimed through a donation that he did not formalize with a public instrument as required by Article 633 of the Civil Code. In a subsequent action (Civil Case No. 936) for ejectment, the court again dismissed his complaint, reasoning that ownership issues were pending in a cadastral case involving the same land. Although the court suggested that if Abellera's title was confirmed in the cadastral case, he could later pursue damages, he did not appeal this decision. In a related 1943 case, the Supreme Court a

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Facts:

Background of the Original Complaint

• The plaintiff, Fabian B. S. Abellera, sought to eject nineteen alleged trespassers or squatters from a tract of land.
• His initial action was based on his claim of title to the hacienda through a donation which he had not executed in a public instrument as required by Article 633 of the Civil Code (Abellera vs. Balanag, 37 Phil. 865).
• The complaint for ejectment was dismissed by the court of first instance of La Union on the ground that the plaintiff had not established title in his own name.

Subsequent Actions and the Cadastral Proceedings

• After the dismissal, the plaintiff filed another ejectment suit (civil case No. 936) against the same defendants.
• This second action was also dismissed because the court found that the title to the tract was being litigated in a pending cadastral case in the same court.
• The court opined that if the title were confirmed in the cadastral case, the plaintiff could then pursue an action for damages.
• The plaintiff's claim in the cadastral case (No. 5 in Aringay, La Union) was compromised when:
• His answers claiming the lots into which the tract had been divided were stricken out.
• He was prevented from presenting evidence to prove his title either to the overall tract or to the individual lots.
• Seeking redress, the plaintiff applied to the Supreme Court for a writ of certiorari to compel the cadastral court to allow the presentation of evidence.
• The Supreme Court granted the petition and reversed the lower court’s order, directing the petitioner to be allowed to present evidence over his claim on the lots.
• The Supreme Court also clarified that it would not prevent him from instituting a new ejectment action based on his asserted title.

The Present Action for Ejectment and Damages

• Following the destruction of the cadastral record during the battle for liberation and the failure of interested parties or the Director of Lands to reconstitute it, the plaintiff brought a new ejectment suit on 5 February 1946.
• This suit was filed against:
• The same defendants as in the previous cases.
• Successors-in-interest and new or additional defendants claiming lots Nos. 5009, 5010, and 5540 within the subject tract.
• The relief prayed for included:
• A judgment declaring him the owner of the tract of land.
• Possession of the lots unlawfully occupied or detained by the defendants.
• Recovery of damages totaling P40,000, in addition to costs and general relief.

The Defendants’ Motion to Dismiss and Subsequent Court Proceedings

• Instead of answering the complaint, the defendants moved to dismiss alleging:
• That the complaint did not state a valid cause of action; and
• That there was another pending action between the same parties for the same cause.
• On 18 June 1946, the trial court sustained the second ground and dismissed the complaint without costs.
• The defendants based their argument on the Supreme Court’s earlier directive in the certiorari case, which advised the plaintiff to assert his claim over the lots in the ongoing cadastral proceedings.
• The plaintiff appealed the dismissal order to the Court of Appeals, which later certified the appeal to the Supreme Court because only questions of law were involved.

Clarification of the Nature of the Present Action

• Although titled “Recurso Declaratorio” and making reference to Rule 66, the suit is in substance an action for ejectment (reivindicacion) and damages.
• The Supreme Court observed that even if the cadastral record were reconstituted and the plaintiff were allowed to present evidence to prove his title in that proceeding, the cadastral court would still be without authority to award damages.
• The Court emphasized the distinction between the roles of the general jurisdiction court (handling ejectment and damages) and the cadastral court (limited to determining title and ordering registration).

Issue:

• Whether the plaintiff’s complaint, which seeks ejectment and damages, states a proper and distinct cause of action despite the existence of pending cadastral proceedings concerning the same tract of land.
• Whether the dismissal of the present action (on the ground that there is another pending action between the same parties for the same cause) is proper.
• Whether the jurisdictional limitations of the cadastral court—in that it can determine title but cannot grant damages—preclude the plaintiff from filing an independent action for ejectment and damages.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)