Case Digest (G.R. No. 80294-95)
Facts:
In Catholic Vicar Apostolic of the Mountain Province v. Court of Appeals (G.R. Nos. 80294–95, Sept. 21, 1988), the petitioner, the Catholic Vicar Apostolic of the Mountain Province (“Vicar”), sought review of the Court of Appeals’ August 31, 1987 Decision in CA-G.R. Nos. 05148 and 05149, which affirmed the Regional Trial Court of Baguio-Benguet’s judgment ordering the Vicar to surrender Lots 2 and 3 of Psu-194357 to the heirs of Juan Valdez and Egmidio Octaviano, respectively. The dispute originated with the Vicar’s September 5, 1962 application for registration of four church-related lots (Lots 1–4) in La Trinidad, Benguet. In 1965, the Court of First Instance confirmed registration in the Vicar’s name. The heirs opposed as to Lots 2 and 3 and, on appeal to the then Court of Appeals (CA-G.R. No. 38830-R), the registration application was dismissed on May 9, 1977 for lack of acquisitive prescription and just title. Motions for reconsideration were denied in August 1977, andCase Digest (G.R. No. 80294-95)
Facts:
- Background and Land Registration Proceedings
- On September 5, 1962, Catholic Vicar Apostolic of the Mountain Province (VICAR) filed with the Court of First Instance of Baguio-Benguet an application to register Lots 1–4 of Psu-194357 (LRC N-91), on which church buildings and school facilities stood.
- On March 22, 1963, the Heirs of Juan Valdez and the Heirs of Egmidio Octaviano opposed registration of Lots 2 and 3, respectively.
- The trial court (Land Registration Court) rendered a decision on November 17, 1965, confirming VICAR’s title to all four lots.
- Appeals and Holdings of Court of Appeals and Supreme Court
- The oppositors appealed to the Court of Appeals in CA-G.R. No. 38830-R. On May 9, 1977, the CA reversed the trial court as to Lots 2 and 3, dismissing VICAR’s registration application for those lots, holding that:
- Predecessors of the private respondents held possession under good-faith claim of ownership from 1906 to 1951.
- VICAR had been bailee in commodatum until 1951 and acquired adverse claim only upon declaring the lots for taxation in 1951.
- VICAR failed to prove acquisitive prescription: no just title for 10-year ordinary prescription, and possession was insufficient for 30-year extraordinary prescription.
- Motions for reconsideration by both sides were denied on August 12, 1977.
- VICAR and the Heirs of Valdez/Pacita Valdez separately petitioned the Supreme Court (G.R. Nos. L-46832 and L-46872); both petitions were denied in January 1978.
- Post-Registration Proceedings Leading to Present Cases
- In December 1978, a motion for execution of the CA decision was denied by the trial court on the ground that no affirmative relief had been granted. A further petition for certiorari and mandamus (CA-G.R. No. 08890-R) was dismissed on May 16, 1979.
- On July 24, 1979, the Heirs of Egmidio Octaviano filed Civil Case No. 3607 for recovery of possession of Lot 3.
- On September 24, 1979, the Heirs of Juan Valdez filed Civil Case No. 3655 for recovery of Lot 2.
- Trial Court and Court of Appeals Decisions in Recovery Cases
- In Civil Case No. 3607, the trial court heard evidence on ownership and possession. VICAR’s witnesses admitted its occupation of Lot 3 only post-1945, and that VICAR never held title before 1962.
- In Civil Case No. 3655, the parties agreed facts were undisputed and submitted whether prior CA/Supreme Court decisions on ownership constitute res judicata.
- On August 31, 1987, the Ninth Division of the CA (CA-G.R. Nos. 05148 & 05149) affirmed the RTC decisions ordering VICAR to surrender Lots 2 and 3 to private respondents, denied damages claims, and held the May 9, 1977 CA decision (CA-G.R. No. 38830-R) and its affirmation by the Supreme Court final on questions of fact and res judicata.
Issues:
- Whether the prior CA decision in CA-G.R. No. 38830-R (May 9, 1977) and its Supreme Court affirmation operate as res judicata, barring relitigation of ownership and possession of Lots 2 and 3.
- Whether VICAR may question the factual findings on possession, just title, and acquisitive prescription underlying CA-G.R. No. 38830-R.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)