Case Digest (G.R. No. 225896)
Facts:
The case involves Carmen Aledro-Ruaa (petitioner) and Lead Export and Agro-Development Corporation (respondent). The dispute centers around two parcels of land, Lots 3014 and 5722, originally registered under the name of Segundo Aledro. Segundo executed two significant contracts concerning these properties: a Contract of Lease with Alfredo A. Rivera on August 4, 1972, for a duration of fifteen years, and a Deed of Absolute Sale with Mario D. Advento on March 24, 1981. Advento subsequently sold the properties to Andres M. Ringor on October 8, 1982. On April 25, 1988, Farmingtown Agro-Developers, Inc. (FADI) leased the properties from Ringor for twenty-five years.
The legal proceedings began with Civil Case No. 95-13, filed on January 31, 1995, by the heirs of Segundo, including the petitioner, against Advento and FADI in the Regional Trial Court (RTC) of Panabo City, seeking a declaration of nullity of the deed and damages. The RTC dismissed the case on March 31, 1997, prom...
Case Digest (G.R. No. 225896)
Facts:
Background of the Case
This case involves a dispute over two parcels of land, Lots 3014 and 5722, registered under the name of Segundo Aledro. The properties were subject to multiple transactions, including a lease agreement and a deed of absolute sale, which led to conflicting claims of ownership and possession.
Initial Transactions
- Lease Agreement (1972): Segundo Aledro executed a 15-year lease agreement with Alfredo A. Rivera on August 4, 1972.
- Deed of Absolute Sale (1981): On March 24, 1981, Segundo allegedly sold the same properties to Mario D. Advento through a deed of absolute sale.
- Subsequent Sale (1982): Advento sold the properties to Andres M. Ringor on October 8, 1982.
- Lease to FADI (1988): On April 25, 1988, Ringor leased the properties to Farmingtown Agro-Developers, Inc. (FADI) for 25 years.
First Case: Civil Case No. 95-13
- Filing: On January 31, 1995, the heirs of Segundo, including petitioner Carmen Aledro-RuAa, filed a complaint against Advento and FADI for nullity of deeds and damages.
- Dismissal: The Regional Trial Court (RTC) dismissed the case on March 31, 1997. The heirs appealed, and the Court of Appeals (CA) remanded the case for further evidence.
- Motion to Dismiss: On September 18, 2003, the heirs filed a motion to dismiss with prejudice, which was granted by the RTC on September 30, 2003. The dismissal became final and executory.
Second Case: Civil Case No. 41-2005
- Filing: Sofia Aledro, Segundo’s widow, filed a complaint in 2005 against Advento for nullity of the deed of sale and quieting of title.
- Ruling: The RTC declared the deed of sale null and void and ordered the removal of clouds on the titles. This decision became final and executory.
Present Case: Civil Case No. 218-10
- Filing: On September 30, 2010, petitioner filed an unlawful detainer case against respondent Lead Export & Agro-Development Corporation (successor of FADI).
- MCTC Decision: The Municipal Circuit Trial Court (MCTC) ruled in favor of petitioner, ordering respondent to vacate the properties.
- RTC Decision: The RTC reversed the MCTC decision, citing lack of jurisdiction and res judicata.
- CA Decision: The CA affirmed the RTC decision, ruling that the case was barred by res judicata and that petitioner’s action had prescribed.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Res Judicata: The dismissal of Civil Case No. 95-13 was not a judgment on the merits. The Court emphasized that technicalities should not prevail over substantial justice, especially when there was no determination of the parties’ rights and liabilities in the first case.
- Better Right to Possess: The certificates of title remained under Segundo’s name, and the subsequent buyers failed to register their deeds of sale. Under the Torrens System, the registered owner (or their heirs) has an indefeasible right to possess the property.
- Prescription and Laches: Actions to recover possession of registered land are imprescriptible. Laches, being an equitable principle, cannot override statutory provisions protecting registered owners’ rights.
Conclusion:
The Supreme Court reinstated the MCTC decision, ruling in favor of petitioner Carmen Aledro-RuAa, and ordered respondent to vacate the properties. The Court emphasized the importance of substantial justice over technicalities and upheld the rights of registered owners under the Torrens System.