Case Digest (G.R. No. 259322)
Facts:
In Catholic Vicar Apostolic of the Mountain Province v. Court of Appeals, Heirs of Egmidio Octaviano and Juan Valdez, G.R. Nos. 80294-95, September 21, 1988, First Division, Gancayco, J., writing for the Court.The petitioner is the Catholic Vicar Apostolic of the Mountain Province (Vicar). The respondents are the Court of Appeals (as respondent in the petition for certiorari) and the private claimants, the Heirs of Egmidio Octaviano and the Heirs of Juan Valdez, who instituted separate recovery-of-possession actions. The litigation concerns Lots 2 and 3 of Plan PSU-194357 (LRC N-91), parcels in La Trinidad, Benguet that carry church and convent improvements.
The dispute began when the Vicar filed an application for registration of Lots 1–4 with the Court of First Instance (land registration court) on September 5, 1962 (LRC N-91). On November 17, 1965 the land registration court awarded registrable title to the Vicar. The Heirs of Juan Valdez and the Heirs of Egmidio Octaviano appealed to the Court of Appeals (docketed CA-G.R. No. 38830‑R). On May 9 (or 4), 1977 the Court of Appeals reversed as to Lots 2 and 3, dismissing the Vicar’s application for registration over those parcels; motions for reconsideration by the oppositors were denied on August 12, 1977.
The Vicar and the oppositors separately sought review in the Supreme Court (G.R. Nos. L‑46832 and L‑46872); on January 13, 1978 both petitions were denied in minute resolutions. Subsequent execution and collateral petitions were unsuccessful (the CFI denied a motion for execution on December 7, 1978; the Court of Appeals dismissed a certiorari/mandamus petition in CA‑G.R. No. 08890‑R on May 16, 1979).
Thereafter the private respondents filed ordinary actions for recovery of possession: Civil Case No. 3607 (419) by the Heirs of Egmidio Octaviano (filed July 24, 1979) and Civil Case No. 3655 (429) by the Heirs of Juan Valdez (filed September 24, 1979). At trial the plaintiffs produced testimony and written demands; the Vicar relied on registration records and admitted long occupation of some parcels while insisting its possession was in the character of owner. The trial court (Regional Trial Court, Baguio and Benguet) ruled in favor of the plaintiffs and ordered recovery of Lots 2 and 3.
The Ninth Division of the Court of Appeals (CA‑G.R. Nos. 05148 and 05149) affirmed the trial court in a Decision dated August 31, 1987, holding that prior factual determinations in CA‑G.R. No. 38830‑R (and the Supreme Court’s denial of review) established that the predecessors of the private respondents had possessed Lots 2 and 3 in claim of ownership in good faith from 1906 to 1951 and that the Vicar had been a bailee in commodatum until it repudiated the trust by declaring the lots for taxation in 1951; hence the Vicar could not establish acquisitive prescription. The Vicar’s motion for reconsideration in the Court of Appeals was denied.
The Vicar then filed the present petition for review on certiorari in the ...(Subscriber-Only)
Issues:
- Whether the prior decision of the Court of Appeals in CA‑G.R. No. 38830‑R, together with the Supreme Court’s denial of review, operates as res judicata and bars relitigation in the subsequent recovery‑of‑possession cases (CA‑G.R. Nos. 05148 and 05149).
- Whether the petitioner acquired ownership of Lots 2 and 3 by purchase or acquisitive prescription (ordinary or extraordinary), or whether it was merely a bailee in commodatum whose repud...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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