Facts:

The case of Fabian B. S. Abellera v. Meynardo M. Farol et al. (G.R. No. 48480) revolves around a dispute over ownership of a piece of land and the proceedings initiated in a cadastral case. The events leading up to this case occurred over several years, with crucial developments starting in 1914 when Fabian B. S. Abellera first filed a suit against Hermegildo Balanag and others for ownership of a hacienda. Ultimately, the Court of First Instance dismissed his complaint on two grounds: the claim was barred by prescription and that Abellera's acceptance of a deed of donation of the land was not formally executed in accordance with the Civil Code. This dismissal was affirmed by the Supreme Court on March 22, 1918 (G.R. No. 11970). Following the affirmance, Abellera attempted to introduce a newly executed public document formally accepting the donation, but this was deemed not new evidence that would warrant a retrial.

In July 1918, Abellera initiated a second suit for recovery

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Facts:

Prior Litigation and Dismissal

• In an earlier case involving the same property, petitioner Fabian B. S. Abellera sued Hermegildo Balanag and others (or their predecessors in interest) alleging ownership of a hacienda.
• The Court of First Instance dismissed Abellera’s complaint on two grounds:
• Prescription in favor of the defendants.
• The deed of donation of the lands had not been formally accepted in accordance with Article 633 of the Civil Code.
• On appeal, this Court affirmed the dismissal on the ground of non-acceptance of the deed of donation (Abellera vs. Balanag, 37 Phil. 865, decided March 22, 1918).

Subsequent Developments Prior to the Cadastral Proceedings

• After the perfection of the appeal, Abellera executed a public document formally accepting the donation.
• He presented the deed of acceptance together with proofs of notification to the donor.
• Abellera attempted to raise the issue in a motion for a new trial, relying on what he presented as evidence of subsequent acquisition of title.
• Nonetheless, the previous decision held that he did not acquire title until execution of the deed and notification thereof, leaving his title unproved at the time of the original action.

The Second Action and the Cadastral Case

• In July 1918, Abellera initiated a second action for recovery of the same land against the same defendants.
• The second suit was later dismissed by the Court of First Instance and the case was transferred to cadastral case No. 5.
• Meanwhile, the hacienda had been subdivided into lots, introducing new complications into the claim regarding specific parcels.

Cadastral Proceedings and the Motion to Dismiss

• When the cadastral case came up for hearing in July 1941 before Hon. Meynardo M. Farol at Aringay, La Union:
• Abellera appeared as the claimant asserting his right over the lots.
• Narciso de Guzman and other adverse claimants appeared.
• The adverse claimants, through counsel, moved to dismiss Abellera’s claim on the grounds of:
• Res judicata arising from the prior decision, and
• Prescription (although the latter was not relevant in the present proceedings).
• The lower court granted the motion, dismissing Abellera’s answer and preventing him from introducing evidence in support of his claim.

Petition for Certiorari

• Abellera challenged the dismissal before this Court by filing a petition for a writ of certiorari.
• His central contention was that the dismissal on grounds of res judicata was improperly applied in the context of cadastral proceedings.

Issue:

• Whether the lower court, in a cadastral proceeding, has the jurisdiction to dismiss a claimant’s answer and bar the presentation of evidence on the ground of a prior judgment (res judicata) when the underlying action had been dismissed.
• Whether the doctrine of res judicata, as applied in ordinary civil cases, may be analogously extended to cadastral cases despite the distinctive objective of the cadastral scheme.
• What is the appropriate role of Rule 132 of the Rules of Court in cadastral proceedings regarding motions to dismiss for lack of proof of title based on prior judgments?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)