Case Digest (G.R. No. 142766)
Facts:
The case involves Narciso Amoroso as the petitioner and Juan Alegre, Jr. as the respondent. The events leading to this case began on November 19, 1954, when Juan Alegre, Sr., the father of the respondent, filed a petition for the reconstitution of titles for several parcels of land, including Cadastral Lots No. 3961 and 3962, before the Court of First Instance (CFI) of Capiz. The CFI set a hearing for May 19, 1955, and subsequently issued an order on May 20, 1955, directing the Register of Deeds to reconstitute the titles. On May 21, 1955, Original Certificates of Title (OCT) Nos. RO-1020 and RO-1021 were issued. However, on May 31, 1955, Narciso Amoroso filed a Motion for Relief, questioning the reconstitution of the titles. The CFI initially set aside the May 20 order on November 4, 1955, but later reinstated it on February 29, 1956. After a series of hearings, the CFI dismissed the petition for reconstitution on October 3, 1957, citing false declarations by Alegre, Sr.
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Case Digest (G.R. No. 142766)
Facts:
Subject Properties: The case revolves around two parcels of land, Cadastral Lots No. 3961 and 3962, subdivisions of Cadastral Lot No. 729 in Barrio Cadimahan, Roxas City.
Initial Reconstitution of Titles: On 19 November 1954, Juan Alegre, Sr. (father of respondent Juan Alegre, Jr.) filed a petition for reconstitution of titles for Lots No. 730, 3961, 3962, and 1383. The Court of First Instance (CFI) granted the petition, and reconstituted titles (OCT Nos. RO-1020 and RO-1021) were issued on 21 May 1955.
Petitioner’s Challenge: Narciso Amoroso (petitioner) filed a Motion for Relief on 31 May 1955, questioning the reconstitution of titles for Lots No. 3961 and 3962. The CFI initially set aside the reconstitution order but later reinstated it on 29 February 1956. Amoroso’s subsequent motion for reconsideration was denied.
Final Decision on Reconstitution: On 3 October 1957, the CFI dismissed the petition for reconstitution and set aside the 20 May 1955 Order, finding Alegre, Sr. had made false declarations in his petition.
Recovery of Possession: On 10 April 1985, Juan Alegre, Jr. filed a complaint for recovery of possession and ownership against Amoroso, claiming Amoroso unlawfully occupied the properties. Amoroso countered that he had acquired the properties from Roque and Matias Severino in 1946 and had been in possession since then.
Trial Court Judgment: The RTC dismissed the case, stating the ownership had already been adjudicated in cadastral proceedings in 1924. The Court of Appeals (CA) remanded the case to the RTC, which ruled in favor of Alegre, Jr. in 1993, finding him the rightful owner based on evidence.
CA Affirmation: The CA affirmed the RTC’s decision, ruling that the 3 October 1957 Decision was a nullity since the 20 May 1955 Order had already become final.
Issue:
- Whether the doctrine of res judicata applies, barring Alegre, Jr.'s recovery of possession based on the 3 October 1957 Decision.
- Whether the suit is barred by laches due to Amoroso’s long-standing possession of the properties.
- Whether the lower courts correctly ruled that Alegre, Jr. is the actual and lawful owner of the properties.
Ruling:
The Supreme Court denied the petition, affirming the CA’s decision. The Court held:
- Res Judicata: The doctrine does not apply because the 3 October 1957 Decision was a nullity, as it was rendered after the 20 May 1955 Order had become final. Moreover, the reconstitution case did not resolve ownership but only the re-issuance of titles.
- Laches: The equitable doctrine of laches does not apply because Alegre, Jr. and his father persistently asserted their rights over the property, despite delays caused by legal proceedings and other circumstances.
- Ownership: The lower courts correctly ruled Alegre, Jr. as the rightful owner based on preponderance of evidence, including certifications from the Bureau of Lands and cadastral lists showing his predecessors as the lawful owners.
Ratio:
- Res Judicata: A reconstitution case does not adjudicate ownership but merely re-issues lost or destroyed titles. Therefore, the 3 October 1957 Decision, which dismissed the reconstitution petition, did not resolve ownership and cannot bar the accion reivindicatoria.
- Laches: Laches requires unreasonable delay in asserting rights. Alegre, Jr. and his father repeatedly sought to reclaim the property, and delays were justified by legal and practical circumstances.
- Preponderance of Evidence: Alegre, Jr. presented stronger evidence of ownership, including certifications from the Bureau of Lands and cadastral records, while Amoroso’s evidence failed to establish his claim. The lower courts’ factual findings, supported by evidence, are binding on the Supreme Court.
Conclusion:
The Supreme Court affirmed the CA’s decision, ruling that Alegre, Jr. is the rightful owner of the properties and that res judicata and laches do not bar his claim.