Title
Cayana vs. Court of Appeals
Case
G.R. No. 125607
Decision Date
Mar 18, 2004
The Supreme Court annuls subsequent transactions and TCTs, ruling in favor of the petitioners in their claim to recover possession of two parcels of land, after the Court of Appeals erroneously stated that there was no identity of causes of action between the two cases.
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Case Digest (G.R. No. 125607)

Facts:

  • The case involves a property dispute among siblings over two parcels of land in Rosario, Lingayen, Pangasinan.
  • Petitioners: Rufina C. Cayana, Josefina C. Rabina, Mercedes C. de Guzman, and Susana C. Sambale.
  • Respondents: Pastor and Marceliano Cayabyab, their spouses, and Marceliano's daughter and her husband.
  • The parcels are covered by TCT No. 29332 and TCT No. 117094.
  • Raymundo Cayabyab, with Eulalia's consent, sold the parcels to Pastor Cayabyab via two Deeds of Absolute Sale dated March 3, 1976, and May 13, 1965.
  • After Raymundo's death on March 20, 1976, Eulalia contested the sales, claiming the deeds were forgeries but later retracted her claim.
  • Eulalia and her children (except Pastor) filed Civil Case No. 15298 to annul the deeds and reconvey the parcels, resulting in a decision declaring the deeds and TCTs null and void.
  • Subsequent transactions involving the parcels led to further litigation in Civil Case No. 15937.
  • The trial court ruled in favor of the plaintiffs, but the Court of Appeals reversed the decision, leading to the present petition before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  1. The decision in Civil Case No. 15298 does not bar the respondents' defenses and counterclaims in Civil Case No. 15937 under res judicata but applies under the doctrine of conclusiveness of judgment.
  2. The subsequent purchasers of the First Parcel were not purchaser...(Unlock)

Ratio:

  1. The principle of res judicata did not apply because there was no identity of causes of action between Civil Case Nos. 15298 and 15937. However, the doctrine of conclusiveness of judgment applied, meaning the final decision in Civil Case No. 15298, which declared the Deeds of Absolute Sale and the corresponding TCTs null and void, precluded further adjudication on their validity in Civil Case No. 15937.
  2. The subsequent purchasers, including Rosafina Reginaldo, the Rural Bank of Urbiztondo, Marceliano and Rosalia Cayab...continue reading

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