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...

Facts:

Parties and Subject Matter

• Carmen Aledro-RuAa (petitioner) filed the appeal by certiorari against Lead Export and Agro-Development Corporation (respondent).
• The dispute centers on the right to possess two parcels of land identified as Lots 3014 and 5722, covered by Original Certificates of Title Nos. (P‑6303) P‑1781 and (P‑6224) P‑1712, respectively.
• The petitioner claims a better right to the property as an heir of the registered owner, Segundo Aledro.

Chain of Title and Transactional History

• Segundo Aledro, the registered owner, executed two transactions on the parcels:
• A Contract of Lease on August 4, 1972 with Alfredo A. Rivera for fifteen (15) years.
• A Deed of Absolute Sale on March 24, 1981 with Mario D. Advento.
• Subsequent transfers involved Advento selling the property to Andres M. Ringor on October 8, 1982.
• On April 25, 1988, Farmingtown Agro-Developers, Inc. (FADI) leased the land from Ringor for twenty-five (25) years.
• Later corporate mergers and name changes resulted in respondent, Lead Export and Agro-Development Corporation, inheriting the possessory rights of FADI.

Antecedent Litigations Involving the Subject Properties

• First Case – Civil Case No. 95‑13
• On January 31, 1995, the heirs of Segundo (including the petitioner) filed a complaint before RTC Branch 34 alleging real action over an immovable, nullity of the deed, and damages.
• On March 31, 1997, the RTC dismissed the complaint.
• An appeal brought the case before the Court of Appeals (CA) which later reversed the RTC decision and remanded for further evidence.
• On September 30, 2003, a motion to dismiss with prejudice was filed by the heirs (through attorney Nilo Aledro), leading the RTC to dismiss the case with prejudice, which became final and executory.

Summary of Contested Issues and Procedural History

• Petitioner argues that the dismissal in Civil Case No. 95‑13 was not a judgment on the merits and should not bar her subsequent action.
• Respondent contends that the dismissal operated as a final adjudication on the merits due to the prejudicial dismissal and the identity of parties, subject matter, and causes of action.
• The question of prescription was also raised, noting that the alleged claims were filed long after the execution of the contested transactions.

Issue:

Res Judicata

• Whether the prior dismissal in Civil Case No. 95‑13, being with prejudice, constitutes a judgment on the merits that should bars the present action.
• Whether the essential requisites for the application of res judicata (final judgment on the merits, jurisdiction, and identity of parties, subject matter, and cause of action) are fully satisfied.

Right to Possession

• Whether the petitioner, as an heir of the registered owner Segundo, possesses a better and indefeasible right to the subject land against the respondent’s claim of possession via lease.
• Whether the respondent’s reliance on unregistered deeds and subsequent transactions can override the registered title under the Torrens system.

Prescription and Laches

• Whether the claims of the petitioner are time-barred by elongated periods since the execution of the contested agreements.
• Whether the rule on imprescriptibility of registered lands applies such that even prolonged inaction does not invalidate the petitioner’s claim.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)