Case Digest (G.R. No. 135365)
Facts:
The case involves Rosario Barbacina as the petitioner against the Honorable Court of Appeals, spouses Richard Gavino and Ma. Olivia Amorin Gavino, Cirilo Farinas, the Register of Deeds of Quezon City, and the National Housing Authority (NHA), formerly known as the People's Homesite and Housing Corporation (PHHC), as respondents. The events leading to this case began when Barbacina filed a complaint for annulment of title against the private respondents before the Regional Trial Court (RTC) of Quezon City. She sought to nullify a Conditional Contract to Sell and a Deed of Sale executed by the NHA in favor of Cirilo Farinas, as well as to cancel Transfer Certificate of Title (TCT) No. 145007 in Farinas's name and TCT No. 383593 in the names of the Gavino spouses. Barbacina claimed that she had been in public, open, and adverse possession of the land for over fifty years, asserting that the NHA's policy was to award lots to occupants. She alleged that her application...
Case Digest (G.R. No. 135365)
Facts:
Petitioner's Claim of Ownership:
- Petitioner Rosario Barbacina filed a complaint for annulment of title, seeking to nullify the Conditional Contract to Sell and Deed of Sale executed by the National Housing Authority (NHA) in favor of respondent Cirilo Farinas.
- She claimed to have been in open, public, and adverse possession of the subject property (Lot 3, Block 131, Quezon City) for over 50 years.
- She alleged that the NHA (formerly PHHC) had a policy of awarding lots to occupants, and she had applied for the award of the property but was ignored.
Award to Cirilo Farinas:
- The property was awarded to Cirilo Farinas, who was allegedly not qualified as he was not a resident or occupant of the property.
- TCT No. 145007 was issued in Farinas' name, with a condition requiring the construction of a residential house within one year, which he failed to comply with.
- Farinas later transferred the property to respondents Richard and Ma. Olivia Gavino, who were issued TCT No. 383593.
Prior Cases and Res Judicata:
- Respondents Gavino filed a motion to dismiss, arguing that the validity of Farinas' title had already been upheld in two prior cases: Civil Case No. Q-28101 and Civil Case No. Q-43359.
- In Civil Case No. Q-28101, the trial court dismissed Barbacina's complaint, ruling that Farinas' ownership could not be overridden by her possession and that the action to annul the title should have been filed within one year of its issuance.
- In Civil Case No. Q-43359, the trial court dismissed Barbacina's petition for injunction on the ground of res judicata, as the issues were the same as those in Civil Case No. Q-28101.
Petitioner's Arguments:
- Barbacina argued that her present complaint was not barred by res judicata because five new issues were raised:
(1) Farinas' qualification as an awardee,
(2) Validity of the award and Deed of Sale,
(3) Farinas' failure to comply with the title condition,
(4) Validity of Farinas' sale to the Gavinos, and
(5) Validity of the Gavinos' title.
- Barbacina argued that her present complaint was not barred by res judicata because five new issues were raised:
RTC and CA Decisions:
- The RTC dismissed Barbacina's complaint, ruling that it was barred by prior judgment.
- The Court of Appeals affirmed the RTC's decision, holding that there was identity of subject matter, causes of action, and parties between the present case and the prior cases.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Res Judicata:
- The Court held that all elements of res judicata were present:
(1) A final judgment was rendered in Civil Case No. Q-28101.
(2) The court had jurisdiction over the subject matter and parties.
(3) There was identity of parties, subject matter, and causes of action between the prior and present cases. - The parties in both cases were substantially the same, as the Gavino spouses were successors-in-interest of Farinas.
- The subject matter (the property) and the causes of action (validity of the NHA's award to Farinas) were identical.
- The Court held that all elements of res judicata were present:
New Issues Raised:
- The Court ruled that even if new issues were raised, they could have been adjudicated in the prior case. The doctrine of res judicata bars not only matters actually litigated but also those that could have been litigated.
Factual Questions:
- The Court emphasized that factual questions, such as Farinas' qualification as an awardee and his compliance with the title condition, are not reviewable in a petition for certiorari under Rule 45.
Validity of Titles and Awards:
- The Court upheld the validity of the titles issued to Farinas and the Gavino spouses, as the prior judgment had already settled the issue of Farinas' ownership.
Finality of Prior Judgment:
- The existence of the order dismissing Civil Case No. Q-28101 was established, despite the destruction of court records, as it was referenced in the decision of Civil Case No. Q-43359.
Conclusion:
The Supreme Court affirmed the dismissal of Barbacina's complaint, holding that the doctrine of res judicata barred her claims. The petition was denied for lack of merit.