Case Digest (G.R. No. 183641)
Facts:
- Benjamin Guerrero is the petitioner; respondents include the Director of the Land Management Bureau, Florante Edward R. Benitez, and the heirs of Marcelo Bustamante, represented by Cora Z. Bustamante.
- Guerrero obtained a miscellaneous sales patent and Original Certificate of Title (OCT No. 0-28) for a 174 square meter parcel of land in Pugad Lawin, Quezon City, on August 27, 1982.
- Angelina Bustamante, wife of Marcelo Bustamante, protested Guerrero's title, claiming it encroached on land subject to Marcelo's patent application.
- The initial protest was dismissed by the Director of Lands and upheld through appeals to the Ministry of Natural Resources and the Office of the President, which dismissed the case on October 10, 1986.
- A motion for reconsideration led to a remand for further investigation on October 30, 1987, and corrective action was directed by the DENR on January 10, 1989.
- The Director of Lands filed a petition for amendments to Guerrero's title with the RTC of Quezon City, which was dismissed on July 13, 1995, for lack of merit.
- The dismissal was affirmed by the Court of Appeals on February 12, 1998, and by the Supreme Court on March 28, 2006, finding no fraud in Guerrero's title acquisition.
- On February 1, 2007, the heirs of Marcelo Bustamante filed another protest, claiming Guerrero's title covered land with Marcelo's house and alleging fraud.
- Guerrero filed a petition for contempt against the respondents for alleged forum shopping.
Issue:
- (Unlock)
Ruling:
- The Supreme Court found that the heirs of Marcelo Bustamante committed forum shopping and were guilty of direct contempt of court.
- The petition to cite the public respondents for indirect contemp...(Unlock)
Ratio:
- The Supreme Court ruled that the heirs of Marcelo Bustamante engaged in forum shopping by filing a protest that repeated claims already resolved in the case of Republic v. Guerrero.
- The principle of res judicata ...continue reading
Case Digest (G.R. No. 183641)
Facts:
The case involves Benjamin Guerrero as the petitioner and the Director of the Land Management Bureau, Florante Edward R. Benitez, and the heirs of Marcelo Bustamante, represented by Cora Z. Bustamante, as respondents. The events leading to this case began when Guerrero obtained a miscellaneous sales patent and subsequently an Original Certificate of Title (OCT No. 0-28) for a 174 square meter parcel of land located in Pugad Lawin, Quezon City, issued by the Register of Deeds on August 27, 1982. The issuance of this title was contested by Angelina Bustamante, the wife of Marcelo Bustamante, who filed a protest claiming that Guerrero's title encroached on land subject to Marcelo's own patent application. The initial protest was dismissed by the Director of Lands and upheld through subsequent appeals to the Ministry of Natural Resources and the Office of the President, which ultimately dismissed the case on October 10, 1986. However, following a motion for reconsideration, the Office of the President remanded the case for further investigation on October 30, 1987, and later directed the Department of Environment and Natural Resources (DENR) to take corrective action regarding the technical description of the property on January 10, 1989.
On November 7, 1989, the Director of Lands filed a petition for amendments to the plan and technical description of Guerrero's title with the Regional Trial Court (RTC) of Quezon City, which was dismissed on July 13, 1995, for lack of merit. This dismissal was affirmed by the Court of Appeals on February 12, 1998, and subsequently by the Supreme Court in the case of Republic of the Philippines v. Benjamin Guerrero on March 28, 2006, ...