Title
Anticamara vs. Ong
Case
G.R. No. L-29689
Decision Date
Apr 14, 1978
Dispute over Lot 1149 ownership; prior judgments (res judicata) bar Anticamara siblings' claim despite new parties. SC affirms dismissal.
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Case Digest (G.R. No. L-29689)

Facts:

  1. Ownership and Lease of Lot 1149:

    • The dispute involves Lot 1149 of the Iligan City cadastre, with an area of 1,800 square meters.
    • On July 3, 1950, Jose Ong, claiming ownership, leased a 390-square meter portion of the lot to Lucas Laspinas for 12 years (1949-1960).
  2. Free Patent and Title Issuance:

    • On June 5, 1956, Jose Ong secured a free patent for the lot, which was registered, and Original Certificate of Title No. P-600 was issued to him on September 25, 1956.
  3. Protest and Legal Actions:

    • On September 9, 1957, Segundina Anticamara (Laspinas' wife) filed a protest with the Bureau of Lands after learning of the patent. The Bureau dismissed her protest, stating the lot had become private property and advised her to pursue her claim in court.
    • Jose Ong filed a complaint for rescission of the lease (Civil Case No. IL-49) and an ejectment suit (Civil Case No. 271) against the Laspinas spouses. The municipal court ordered the Laspinas spouses to vacate the leased portion.
  4. Appeal and Lower Court Decision:

    • The Laspinas spouses appealed to the Court of First Instance, which declared Jose Ong the owner of the lot and ordered the defendants to deliver possession to Ong. The Court of Appeals affirmed this decision on October 29, 1966.
  5. Subsequent Action by Anticamara Siblings:

    • On March 30, 1968, Segundina Anticamara, along with her siblings Paterna, Obdulia, and Simeon, filed a case (Civil Case No. 1297) to establish ownership over Lot 1149. They claimed their parents inherited the lot from Carlos and Leocadia Ong in 1926 and that Jose Ong fraudulently secured the free patent.
  6. Defendants' Motion to Dismiss:

    • The defendants moved to dismiss the complaint, arguing res judicata, prescription, and indefeasibility of Torrens title. The lower court dismissed the case on these grounds.
  7. Execution of Ejectment Judgment:

    • The defendants stated that the ejectment judgment had been executed, the Laspinas spouses' house had been demolished, and they were in exclusive possession of the lot.

Issue:

  1. Whether the plaintiffs' action is barred by res judicata due to prior judgments in Civil Cases Nos. IL-49 and IL-97.
  2. Whether the plaintiffs' action is barred by prescription.
  3. Whether the lower court had jurisdiction to review the issuance of the free patent and Torrens title.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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