Case Digest (G.R. No. L-25894)
Facts:
The case involves Quirino Bolanos, Edilberto Alejandrino, and Diosdado de los Reyes as petitioners-appellees against J. M. Tuason & Co., Inc. and People's Homesite & Housing Corporation as respondents-appellants. The events leading to this case began with a civil action filed by J. M. Tuason & Co., Inc. against Quirino Bolanos in the Court of First Instance of Rizal, Quezon City Branch, seeking to recover possession of a parcel of land. The court ruled in favor of Tuason, and Bolanos subsequently appealed to the Supreme Court, which affirmed the lower court's decision on May 28, 1954. In a separate set of civil cases (Nos. 3621, 3622, and 3623), the same court declared Original Certificate of Title No. 735 as null and void due to jurisdictional defects in the registration process. The petitioners, claiming possession of the land in question, filed an urgent petition on March 17, 1965, requesting an order to prevent any disturbance of their possession until...
Case Digest (G.R. No. L-25894)
Facts:
Background of the Case:
- The case involves a dispute over the possession of a parcel of land comprising 13.2619 hectares, covered by Transfer Certificates of Title (TCT) Nos. 37677 and 37686, registered under J. M. Tuason & Co., Inc.
- Quirino Bolanos, one of the petitioners, was in possession of the land at the time the civil action was instituted and remained in possession up to the time of the petition.
Previous Litigation:
- In a prior case, J. M. Tuason & Co., Inc. vs. Quirino Bolanos (G.R. No. L-4935, May 28, 1954), the Supreme Court affirmed the lower court's decision declaring Bolanos without any right to the land and ordering him to restore possession to Tuason.
- Despite this decision, Bolanos remained in possession of the land, and the decision had not been executed for over ten years.
Current Petition:
- In Civil Cases Nos. 3621, 3622, and 3623, the Court of First Instance of Rizal declared Original Certificate of Title (OCT) No. 735 null and void. The petitioners argued that since TCT Nos. 37677 and 37686 were derived from OCT No. 735, these titles should also be declared null and void.
- The petitioners sought an injunction to prevent anyone from disturbing Bolanos' possession of the land pending the finality of the decision in the aforementioned civil cases.
Publication of the Petition:
- The petition was published in the Daily Mirror on May 22, 29, and June 5, 1965, at the petitioners' expense.
Lower Court's Order:
- The Court of First Instance of Rizal granted the petition, enjoining all parties from disturbing Bolanos' possession of the land.
Issue:
Res Judicata:
- Whether the petition is barred by the judgment in J. M. Tuason & Co., Inc. vs. Quirino Bolanos (G.R. No. L-4935), which had already ruled on the validity of Tuason's titles and Bolanos' lack of right to the land.
Jurisdiction of the Lower Court:
- Whether the lower court had jurisdiction to issue the injunction, given that the land registration court's jurisdiction is limited to matters related to the issuance of a writ of possession after the original registration proceedings have concluded.
Execution of the Supreme Court's Decision:
- Whether the lower court erred in assuming that the Supreme Court's decision in G.R. No. L-4935 had not been executed and that Bolanos was still in possession of the land.
Validity of the Order:
- Whether the lower court erred in issuing the order dated August 5, 1965, enjoining all parties from disturbing Bolanos' possession of the land.
Ruling:
The Supreme Court ruled in favor of the respondents-appellants, J. M. Tuason & Co., Inc. and the People's Homesite & Housing Corporation. The Court held that:
Res Judicata:
- The petition was barred by the judgment in J. M. Tuason & Co., Inc. vs. Quirino Bolanos (G.R. No. L-4935), which had already resolved the issue of the validity of Tuason's titles and Bolanos' lack of right to the land.
Lack of Jurisdiction:
- The lower court, acting as a land registration court, had no jurisdiction to issue the injunction. The jurisdiction of the land registration court is limited to matters related to the issuance of a writ of possession after the original registration proceedings have concluded.
Invalidity of the Order:
- The lower court's order was issued beyond its jurisdiction and was therefore null and void.
Ratio:
Res Judicata:
- The doctrine of res judicata applies, as the issue of the validity of Tuason's titles and Bolanos' lack of right to the land had already been conclusively decided in J. M. Tuason & Co., Inc. vs. Quirino Bolanos (G.R. No. L-4935).
Jurisdiction of the Land Registration Court:
- The land registration court's jurisdiction is limited to matters related to the issuance of a writ of possession after the original registration proceedings have concluded. It does not have jurisdiction to resolve issues of possession after the original registration proceedings have ended and a writ of possession has been issued.
Auxiliary Remedy:
- An auxiliary remedy, such as an injunction, cannot be granted unless there is a principal remedy to which it pertains. In this case, there was no pending action or proceeding in which the petitioners were seeking to annul Tuason's titles.
Due Process:
- The declaration of nullity of OCT No. 735 in Civil Cases Nos. 3621, 3622, and 3623 does not automatically affect other titles derived from it, especially when the holders of those titles have not been heard or notified. This is a fundamental principle of due process.
Conclusion:
The Supreme Court declared the lower court's order null and void, ruling that it was issued beyond the court's jurisdiction. The Court emphasized that the land registration court's jurisdiction is limited to matters related to the issuance of a writ of possession after the original registration proceedings have concluded. The Court also reiterated the doctrine of res judicata, holding that the issue of the validity of Tuason's titles and Bolanos' lack of right to the land had already been conclusively decided in a prior case.