G.R. No. 182497 - Ampatuan vs. Macaraig

The subject matter is a parcel of land located at Barrio Sicaba, Cadiz City, Negros Occidental, which is a portion of Lot No. 1536-B (formerly Lot No. 591-B) originally owned by Esteban Dichimo and his wife, Eufemia Dianala.
The land became the subject of several lawsuits following the death of the original owners, with competing claims by different groups of heirs.

On September 27, 1976, a Complaint for Recovery of Possession and Damages was filed in the Court of First Instance (now RTC) of Negros Occidental, docketed as Civil Case No. 12887.
Petitioner’s wife, Margarita Dichimo, along with other relatives, claimed inheritance as heirs of Vicente Dichimo, while other complainants claimed to be heirs of Eusebio Dichimo, asserting that both Vicente and Eusebio were the compulsory heirs of Esteban and Eufemia who died intestate.

On July 29, 1983, respondents intervened by filing an Answer-in-Intervention. They claimed that prior to his marriage to Eufemia, Esteban was married to Francisca Dumalagan and that their five children (all deceased) were the true heirs.
Respondents asserted that they had been in open, actual, public, and uninterrupted possession of a portion of Lot No. 1536-B for more than 30 years, and that petitioner's heirs had already disposed of their share.
Subsequently, on November 26, 1986, the trial court dismissed respondents’ Answer-in-Intervention without prejudice because they failed to secure counsel, effectively removing them as active parties in Civil Case No. 12887.

After Civil Case No. 12887 went to trial, the parties entered into a Compromise Agreement dividing Lot No. 1536-B between Jose Maria Golez and the heirs of Vicente (Margarita, Bienvenido, and Francisco). The agreement was approved by the RTC of Bacolod City, leading to the issuance of TCT No. T-12561.
On January 18, 1999, petitioner and his co-heirs filed a separate Complaint for Recovery of Possession and Damages (Civil Case No. 548-C) against respondents.
In response, respondents on August 18, 1999, filed a Complaint for Reconveyance and Damages in Civil Case No. 588-C. The cases were eventually consolidated.

Motion to Dismiss Civil Case No. 548-C was granted and the case was dismissed due to forum shopping.
Motion to Dismiss Civil Case No. 588-C was also granted for want of jurisdiction.
All counterclaims in both cases were dismissed.

Motions for reconsideration filed by both parties were denied by the RTC in an Order dated October 5, 2000.
Respondents then appealed the dismissal of Civil Case No. 588-C to the Court of Appeals (CA), seeking to have the matter tried on the merits.
On January 12, 2005, the CA rendered a decision setting aside the RTC’s Joint Orders dismissing Civil Case No. 588-C and remanded the records for trial on the merits.
Petitioner filed a Motion for Reconsideration before the CA, which was denied in a Resolution dated February 13, 2006.

Petitioner argued that respondents, having filed an Answer-in-Intervention, should be considered parties to the original Civil Case No. 12887 and thus bound by its judgment.
He contended that the CA erred in asserting that respondents are strangers to the said case after their Answer-in-Intervention was dismissed.
Additionally, petitioner asserted that respondents’ reconveyance action was barred by prescription and that the RTC of Cadiz City lacked jurisdiction to grant the reconveyance claim, as it could not effectively amend or annul the RTC’s decision in Civil Case No. 12887.

Whether respondents, although initially parties by filing an Answer-in-Intervention, lost their status as parties in Civil Case No. 12887 upon the dismissal of their intervention, thereby rendering them strangers to that case and not bound by its judgment.
Whether the filing of the Complaint for Reconveyance and Damages (Civil Case No. 588-C) is proper and timely, considering the applicable prescriptive period for an action based on fraud and implied trust.
Whether the RTC of Cadiz City had proper jurisdiction to hear the reconveyance action filed by respondents, notwithstanding the existence and prior resolution of Civil Case No. 12887.
Whether the claims of prescription and laches raised by petitioner are applicable in disallowing respondents’ reconveyance action, particularly in light of statutory provisions and the doctrine of imprescriptibility when the plaintiff is in possession.