Facts:

The case involves a Petition for Review filed by Evangeline Engao Asis and the heirs of Felicitation Engao-Bautista and Erma Engao-Trocino (collectively referred to as Petitioners) against the heirs of Rosello Calignawan (Respondents). The case was heard by the Second Division of the Philippine Supreme Court under G.R. No. 242127, with a decision rendered on September 15, 2021. The original legal battle began in a Regional Trial Court (RTC) in Tacloban City, where it was established that the spouses Cesario and Romana Engao had two children: Felipe Engao and Angeles Engao-Calignawan. The conflict arose concerning two properties registered under the names of Romana and Angeles. Respondents' ancestor, Rosello Calignawan, claimed that he was entitled to a share of these properties based on a Deed of Donation executed by Angeles in his favor. The RTC made a ruling in 2009 that these properties belonged to Romana and Angeles, declaring that Rosello was not an heir, and invalidate

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Facts:

Parties and Family Relations

• Petitioners
• Evangeline Engao Asis
• Heirs of Felicitacion Engao-Bautista: Fernando B. Bautista, Agueda Fe B. Bautista, Fernando E. Bautista, Jr.
• Heirs of Erma Engao Trocino: Felipe E. Trocino and Pamela T. Dela Cruz
• Cesar A. Engao
• Respondents
• Heirs of Rosello Calignawan: Erlinda, Vincent, Lindro, Sherman, Marvi, Ian Loyd, Gary Martin, and Mary Rose Calignawan
• Family Background
• The Spouses Engao – Cesario and Romana Engao – are the progenitors of Felipe and Angeles Engao.
• Felipe, having four children (including petitioners Evangeline, Erma, Felicitacion, and Cesar), and Angeles served as the basis of the contested inheritance.
• Rosello Calignawan, coming from a different familial background, is connected to the respondents through his father, who grew up with Vicente and Angeles Calignawan.

Subject Properties and Documentation

• Description of Properties
• Subject properties include Lot No. 581 and Lot No. 2064 located on M.H. del Pilar Street, Tacloban City.
• Originally registered under the names of Romana and Angeles using TCT Nos. T-1084 and T-1051 respectively.
• Chain of Title and Documentation Issues
• Cancellation of original certificates of title upon discovery by Rosello during updating of tax declarations in 1988.
• Issuance of new transfer certificates (TCT Nos. T-26416, T-26418, T-26419, T-26415, and TCT T-26417) involving petitioners and Rosello.
• Documents in Dispute
• Deed of Donation allegedly executed by Angeles in favor of Rosello, subject to allegations of forgery and undue influence.
• Deed of Adjudication of the Estate of the Deceased Persons and Deed of Consolidation and Subdivision of Real Properties dated December 2, 1982, which led to cancellation of the original titles and issuance of new ones.
• Extrajudicial Settlement executed in 1985 to ostensibly remedy or correct the earlier deeds.

Chronology and Procedural History

• Filing and Handling of Cases
• Rosello filed a Complaint for Declaration of Nullity of Documents, Partition, and Damages with Preliminary Injunction in the RTC, leading to Civil Case No. 89-01-005 in Branch 9, Tacloban City (decided December 16, 2009).
• Separate litigation arose when Rosello filed a subsequent case (Civil Case No. B-92-10-461) in the RTC of Burauen, Leyte, alleging ownership and possession issues.
• Arguments Presented by the Parties
• Petitioners maintained that the Deed of Donation was void, contending that Angeles was physically unfit to execute such a document; they cited inconsistencies in notarization procedures and timing of discovery.
• Respondents (and Rosello) argued that the Deed of Donation was valid and that other documents (Deed of Adjudication, Consolidation, and the Extrajudicial Settlement) were null due to involving future inheritance.
• Pre-Trial and Trial Developments
• Pre-Trial Orders streamlined the issues to:
• Ownership of the subject properties (whether under the Spouses Engao or Romana and Angeles individually).

ii. Validity and effect of the Deed of Donation. iii. The propriety of the remedies sought (including partition, nullification of documents, and claims for damages).

Contentions on Forum-shopping and Res Judicata

• Allegation of Forum-shopping
• Petitioners claimed that Rosello split his cause of action by filing separate complaints in different RTCs (Tacloban City and Burauen, Leyte).
• They argued that such splitting constitutes wilful forum-shopping designed to obtain conflicting determinations.
• Res Judicata and Finality of Prior Decisions
• Petitioners argued that the RTC decision in Tacloban should be immune from challenge since it was rendered before the RTC of Burauen’s decision attained finality.
• Respondents contended that the final adjudication on the validity of the Deed of Donation had already been established through decisions rendered by the RTC of Burauen, later affirmed by the Court of Appeals (CA) and even this Court in G.R. No. 188676.

Appellate and Supreme Court Developments

• Court of Appeals (January 18, 2018 Decision)
• Held the Deed of Adjudication, Consolidation, and Extrajudicial Settlement as null and void.
• Validated the Deed of Donation based on prior rulings and the doctrine of res judicata.
• Ordered cancellation of the new titles and reinstatement of the originals, as well as the partition of the subject properties per the de facto arrangements.
• Supreme Court Review
• Petitioners raised additional issues regarding jurisdiction, forum-shopping, and abuse of procedural rules (such as the late filing of briefs).
• The Supreme Court reviewed the matter in light of the principles of res judicata and proper exercise of judicial discretion in admitting lateness of filings.

Issue:

Validity of the Deed of Donation

• Whether the Deed of Donation executed by Angeles in favor of Rosello was valid or void.
• Whether the alleged forgery or undue influence in obtaining Angeles’ signature can be substantiated given the evidentiary record.

Nullity of Related Documents

• Whether the Deed of Adjudication, the Deed of Consolidation, and the Extrajudicial Settlement are valid instruments or should be declared null and void based on being instruments involving future inheritance and improper execution.

Allegation of Forum-shopping

• Whether Rosello (or his predecessor) committed forum-shopping by filing two separate complaints (one in Tacloban City and one in Burauen) for essentially the same cause of action.
• Whether raising the forum-shopping issue only on appeal constitutes a waiver of the defense.

Application of Res Judicata and Procedural Issues

• Whether the decisions rendered by the RTC of Burauen and the subsequent affirmation regarding the Deed of Donation’s validity create res judicata that precludes re-litigating identical issues in the RTC of Tacloban.
• Whether the appellate court was justified in its exercise of judicial discretion in admitting the belated filing of the Appellant’s Brief, despite allegations of procedural lapses.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)