Case Digest (G.R. No. 185169)
Facts:
This is Heirs of Catalino Dacanay et al. v. Juan Siapno, Jr., et al., G.R. No. 185169, June 15, 2016, First Division, Sereno, C.J., writing for the Court. Petitioners are the alleged heirs of Esperanza Espiritu (collectively petitioners); respondents are Juan Siapno, Jr., Mario Rillon, and Spouses Jose Sy Tan and Leticia Dy Tan (collectively respondents). The case arose from competing claims over a 13,165-square-meter parcel in Barangay Olo-Cacamposan, Mangatarem, Pangasinan, originally appearing under OCT No. P-13438 in the name of the heirs of Esperanza Espiritu.The title passed through several transfers: in 1995 OCT No. P-13438 was cancelled and TCT No. 202765 issued to Siapno; in April 1996 TCT No. 202765 was cancelled and TCT No. 212328 issued to Sps. Tan. Petitioners allege the transfers were tainted by fraud: an Affidavit of Declaration of Heirs purportedly executed by Catalino Dacanay on 16 December 1994 misidentified his status and enabled a Deed of Absolute Sale to Siapno, who then sold to Sps. Tan on 19 March 1996. Petitioners attached Catalino’s marriage contract to show he was married in 1994 and thus not the sole heir as represented.
Separately, Rillon, claiming to be Catalino’s tenant, filed a complaint before the Department of Agrarian Reform Adjudication Board (DARAB Case No. 9631), asserting he had been denied his right of redemption under R.A. No. 3844, as amended by R.A. No. 6389; on 3 July 2006 the DARAB adjudicated the land to Rillon as a bona fide tenant entitled to redeem, and that decision became final and executory.
On 7 May 2008 petitioners filed a Complaint in RTC Branch 69, Lingayen, Pangasinan, seeking declaration of nullity of the Affidavit of Declaration of Heirs, the Deeds of Sale, cancellation of TCTs and tax declarations, reversion and partition of the land among heirs, and damages. Siapno, Sps. Tan, and Rillon filed answers with compulsory counterclaims raising venue, prescription, lack of cause of action, and asserting that the DARAB Decision vested title in Rillon. The RTC, noting the DARAB decision’s finality, dismissed the complaint on 8 September 2008 on the ground of res judicata and futility, reasoning that DARAB had effectively vested title in Rillon and that nothing remained to partition; the RTC denied petitioners’ motion for reconsideration on 13 October 2008.
Petitioners elevated the case directly to the Supreme Court by a Petition for Review on Certiorari under Rule 45 claiming the RTC erred in applying res judicata, since they were not parties to the DARAB case and the causes of action differed. The Supreme Court issued resolutions directing compliance with certain formalities; petitioners’ counsel, Atty. Eugenio F. Manaois, repeatedly failed to comply, prompting the Court to institute motu proprio disciplinary proceedings and to refer the matter to the Integrated Bar of the Philippines (IBP).
Issues:
- Did the Regional Trial Court commit grave error of law in dismissing petitioners’ Complaint on the ground of res judicata pursuant to the DARAB Decision in DARAB Case No. 9631?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)