Case Digest (G.R. No. 173148)
Facts:
- The case involves a property dispute over land on the northeastern bank of the Jalaud River in Iloilo, Philippines.
- Petitioner Elsa Degayo claims ownership of the disputed land as an accretion to Lot No. 861, originally owned by her deceased parents.
- Respondents, including Cecilia Magbanua-Dinglasan and others, own Lot No. 7328 on the opposite bank of the river.
- In the 1970s, the Jalaud River shifted southward, drying up its old riverbed and altering the land areas adjacent to Lots No. 861 and No. 7328.
- Degayo and her tenants began cultivating the new land area, considering it part of Lot No. 861.
- Respondents argued that the disputed land was an abandoned riverbed, compensating for the river's encroachment on Lot No. 7328.
- Respondents filed a complaint for ownership and damages in the RTC of Iloilo, Branch 27 (Civil Case No. 16047), where Degayo's motion to intervene was denied.
- Degayo subsequently filed a separate suit for declaration of ownership with damages in the RTC of Iloilo, Branch 22 (Civil Case No. 18328).
- The RTC Branch 27 ruled in favor of the respondents, and the decision became final and executory.
- The RTC Branch 22 ruled in favor of Degayo, but the Court of Appeals reversed this decision, declaring the land as an abandoned riverbed.
- Degayo filed a petition for review on certiorari with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition for lack of merit, affirming the Court of Appeals' decision that the disputed property is a...(Unlock)
Ratio:
- The Supreme Court held that the decision in Civil Case No. 16047 constitutes res judicata, meaning the matter has already been adjudged and cannot be litigated again.
- Res judicata promotes judicial efficiency and prevents inconsistent decisions, making a final court judgment conclusive of the parties' rights in all later suits on determined points and matters.
- The Court found identity of parties and issues between Civil Case No. 16047 and the present case, with Deg...continue reading
Case Digest (G.R. No. 173148)
Facts:
The case "Degayo v. Magbanua-Dinglasan" revolves around a property dispute concerning a parcel of land situated on the northeastern bank of the Jalaud River in Iloilo, Philippines. The petitioner, Elsa Degayo, asserts ownership over the disputed property, claiming it as an accretion to Lot No. 861, a 36,864 sq.m. parcel covered by Transfer Certificate of Title (TCT) No. T-2804, registered in the names of her deceased parents, Marcelo Olmo and Rosalia Labana. The respondents, Cecilia Magbanua-Dinglasan, Johnny Dinglasan, Pascualito Magbanua, Mariano Magbanua, Asuncion Magbanua-Porras, and Amado Magbanua Jr., collectively own Lot No. 7328, a 153,028 sq.m. parcel on the opposite side of the Jalaud River, covered under TCT No. T-84829.
In the 1970s, the Jalaud River altered its course, moving southwards and leaving its old riverbed dry. This shift resulted in the encroachment of the river on Lot No. 7328, reducing its size while increasing the land area adjacent to Lot No. 861. Degayo and her tenants began cultivating the newly surfaced area, believing it to be an accretion to Lot No. 861. Conversely, the respondents contended that the disputed property was an abandoned riverbed, which should belong to them as compensation for the portion of Lot No. 7328 now occupied by the river.
The respondents filed a complaint for ownership and damages against Degayo's tenants in the Regional Trial Court (RTC) of Iloilo, Branch 27, docketed as Civil Case No. 16047. Degayo's motion to intervene in this case was denied, and she did not file a petition for certiorari to challenge this denial. Instead, she initiated a separate suit for declaration of ownership with damages in the RTC of Iloilo, Branch 22, docketed as Civil Case No. 18328. The RTC Branch 27 ruled in favor of the respo...