Title
Catholic Vicar Apostolic of the Mountain Province vs. Court of Appeals
Case
G.R. No. 80294-95
Decision Date
Sep 21, 1988
Dispute over ownership of La Trinidad lots; VICAR's claim denied due to res judicata, insufficient possession for acquisitive prescription.
A

Case 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)

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