Case Digest (G.R. No. 10029)
Facts:
In Heirs of Eutiquio Elliot, represented by Meriquita Elliot, Johul Elliot, Rene Elliot, and Perfecto Elliot (petitioners) vs. Danilo Corcuera (respondent), the dispute centers on a 34,264-square-meter parcel in Calapacuan, Subic, Zambales, covered by Original Certificate of Title No. P-7061 issued in Corcuera’s name. On July 12, 2006, Corcuera, through his attorney-in-fact, filed a complaint for recovery of possession and damages in the Regional Trial Court (RTC) of Olongapo City (Civil Case No. 279-0-2006), alleging he was the registered owner and tax declarant of the lot. He claimed that petitioners entered the property in mid-1994 without consent, planted trees, and refused demands to vacate. Petitioners answered on May 29, 2007, arguing the complaint was premature due to an administrative protest before the DENR and that Corcuera’s title was irregular. After trial, the RTC dismissed Corcuera’s complaint on March 4, 2015, holding petitioners had acquired ownership by acquisiCase Digest (G.R. No. 10029)
Facts:
- Original Action for Recovery of Possession and Damages
- Respondent Danilo Corcuera held Original Certificate of Title No. P-7061 over Lot 11122 (34,264 sqm) in Calapacuan, Subic, Zambales, with corresponding tax declarations.
- In mid-1994, petitioners (Heirs of Eutiquio Elliot) entered the lot without consent, cultivated it, and refused demands to vacate. Corcuera filed his complaint on July 12, 2006.
- Petitioners’ Defenses and Administrative Protest
- Petitioners filed a protest before the DENR to annul Free Patent No. (111-4)005010 (OCT No. P-7061), raising a prejudicial question and arguing non-compliance with barangay conciliation.
- They asserted that Corcuera had ceded a portion of the lot (14,093 sqm) to Juanita Filipinas, who pursued her own forcible entry suit and held a separate title.
- Trial Court Ruling (RTC Branch 72, Olongapo City, March 4, 2015)
- Found Corcuera not in possession at the time of intrusion; DENR Certificate of Finality declared his title irregular and obtained by fraud.
- Held petitioners had acquired ownership by acquisitive prescription through open, continuous, exclusive, and adverse possession since 1965; dismissed Corcuera’s complaint for lack of merit.
- Court of Appeals Proceedings and Ruling (CA-G.R. CV No. 105502)
- Reversed on March 20, 2017: concluded petitioners’ evidence was inadmissible (not formally offered) and upheld the presumption of regularity of OCT No. P-7061, entitling Corcuera to possession despite DENR findings.
- Denied petitioners’ motion for reconsideration on August 16, 2017.
- Parallel Nullification Proceedings (G.R. No. 231304)
- In 2009 petitioners sued to nullify Corcuera’s free patent and derivative OCT for fraud in his application, especially over the 14,093 sqm portion.
- RTC (March 4, 2015) ordered reconveyance of that portion; CA affirmed December 15, 2016; SC denied Corcuera’s petition for review July 12, 2017 (Resolution final).
Issues:
- Whether the doctrine of res judicata by conclusiveness of judgment in G.R. No. 231304 bars relitigation of petitioners’ ownership over the 14,093 sqm portion of Lot 11122.
- Whether Corcuera, as certificate holder, has a better right to possess the entire lot over petitioners who claim ownership by acquisitive prescription.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)