G.R. No. 106314-15 - Heirs of Cabais vs. Court of Appeals

Petitioners are the legal heirs of Pedro Cabais—namely, Magdalena Bonto Cabais, Antonio Cabais, Pablo Cabais, Andrea Cabais, Efren Cabais, Agapita Cabais, and Andres Cabais (with Avelina Cabais representing the heir group).
Respondents include heirs of Victoria CaAeta and other persons involved in the earlier land dispute, such as Constancia Paglinawan, Paulino Loria, Aurea Nicolas, Antonio Lo, Santos Wanton, Zenaida Bataller, Isabel Loria, Adelaida Dausa, and Emma Carali, as well as heirs of other individuals with interests in the property.
The subject property is a parcel of land located in Basud, Tabaco, Albay, measuring 1,638 square meters, originally inherited by Pedro Cabais from his grandmother, Eustaquia CaAeta, by right of representation.
Pedro Cabais executed a Deed of Self-Adjudication, transferring the property in his favor, which led to the cancellation of Original Certificate of Title No. RO-3433 (23899) and the issuance of Transfer Certificate of Title No. T-55640 in his name.

Pedro Cabais inherited the property from his grandmother, with his mother, Felipa CaAeta Buesa, having predeceased Eustaquia CaAeta, leaving Pedro as the sole legal heir.
Soon after self-adjudicating the property on October 15, 1979, a complaint for partition and accounting was filed in Civil Case No. T-567, initiated by Simon Bonaobra, heirs of Victoria CaAeta, and heirs of Anastacio CaAeta.
The complaint was dismissed as the plaintiffs were declared non-suited.

During the pendency of Civil Case No. T-567, following Pedro Cabais’ death, respondents entered the property and constructed houses thereon, effectively depriving the petitioners of possession.
Petitioners filed Civil Case No. T-1283 on April 15, 1987, seeking quieting of title, recovery of possession, and ownership because of the cloud cast on their title.
Respondents countered with an Answer asserting lack of cause of action for petitioners, invoking estoppel and alleging that the issuance of TCT No. 55640 derogated their successional rights.
Respondents also filed Civil Case No. T-1284 for annulment of the title and damages, claiming co-ownership of the property and alleging that the cancellation of the original certificate and issuance of the new title were tainted by fraud.
The lower court jointly tried Civil Cases T-1283 and T-1284 and on September 28, 1989, issued a Joint Decision favoring petitioners—quieting their title and ordering respondents to vacate the property and pay rental proceeds to petitioners—while ruling that res judicata barred Civil Case No. T-1284 because of the earlier dismissal of Civil Case No. T-567.

Respondents presented a motion for reconsideration of the Joint Decision, which was granted by the trial court on November 26, 1989. The court reversed its earlier decision primarily by relying on the baptismal certificate of Felipa CaAeta Buesa to challenge the established filiation.
Petitioners contended that the lower court erred in relying on this private document, arguing that the baptismal certificate held limited evidentiary value compared to a birth certificate, which is a public document providing prima facie evidence.
The contentious issue centered on whether the baptismal certificate was sufficient to establish the true parentage of Pedro Cabais and, by extension, determine the rightful succession of the property.

Petitioners appealed the trial court’s reconsideration order to the Court of Appeals, which, in a decision dated November 13, 1991, affirmed the trial court’s revised ruling based on the evidentiary issue regarding the baptismal certificate.
A motion for reconsideration was filed by the petitioners in the Court of Appeals, but it was denied on July 9, 1992.
Petitioners then elevated the case to the Supreme Court seeking review of the appellate decisions.

The baptismal certificate of Felipa CaAeta Buesa was scrutinized for its inconsistency, notably indicating an implausible birthdate (September 13, 1899) relative to the certificate of Gregoria CaAeta, which suggested a birthdate of May 9, 1898.
The marked chronological improbability raised questions regarding the legitimacy of the certificate as proof of filiation and cast doubt on the lower court’s reliance on this document.
This evidentiary discrepancy formed a core part of the petitioners’ argument that the reconsideration was unwarranted and legally unsound.

Whether the trial court erred in granting a motion for reconsideration of its Joint Decision by giving undue weight to the baptismal certificate of Felipa CaAeta Buesa in establishing the filiation of Pedro Cabais.

Does a baptismal certificate, as a private and hearsay document, have sufficient probative weight to establish parentage compared to the official birth certificate?
Was the reliance on the baptismal certificate legally and factually justified in overturning the original quieting of title decision?

Whether the dismissal of Civil Case No. T-567 (for partition and accounting) precludes the filing of Civil Case No. T-1284 (for annulment of title) under the doctrine of res judicata.

Does the absence of identity in the causes of action between the two cases negate the barrier effect of res judicata?
Should the separate nature of the evidentiary requirements and legal issues in each action be considered in precluding the application of res judicata?