G.R. No. 211755 - Heirs of Gabule vs. Jumuad

The dispute arises from conflicting claims over a residential lot originally acquired by the late Felicisimo Gabule, whose title (OCT No. 1817) was allegedly obtained through questionable means.
Prior to the present action, a similar reconveyance case (Civil Case No. 2973, Saldua v. Heirs of Felicisimo Gabule) was filed by Severino Saldua, who claimed ownership over Lot No. 2857-B on the grounds of fraudulent inclusion in Gabule’s title.
In Saldua’s case, it was established that after several transactions—including a barter and multiple sales involving Saldua and third parties—the remaining parcel of the original Lot No. 2857 was reduced and re-designated as Lot No. 2857-B, thereby nullifying Saldua’s further interest after subsequent dealings.

Respondent Felipe Jumuad, who had previously been the sole owner of a certain lot along Alano Street in Pagadian City, sold a one-half (A12) portion of his property to Saldua.
Saldua subsequently sold part of this property to Antonio Langga, while the remaining or “middle” portion (approximately 150 square meters) eventually was conveyed to Hermogenes Daniel and later to Rev. Diosdado Aenlle.
Gabule acquired his portion of land from Rev. Aenlle, but during his application for a certificate of title, he fraudulently included, by misrepresentation, a portion belonging to Saldua and even encroached upon part of the respondent’s property, resulting in a discrepancy between the deed of sale (stating an area of about 156.25 sq. m.) and the OCT which showed 337 sq. m.

In the initial litigation (Civil Case No. 3075), respondent Felipe Jumuad filed an action for reconveyance and damages against the heirs of Felicisimo Gabule, alleging that fraudulent misrepresentation by Gabule led to the wrongful inclusion of part of his property (Lot No. 2857-B-1) in the OCT.
The Regional Trial Court (RTC) of Pagadian City, Branch 19, rendered a favorable decision for respondent on May 10, 2006, finding that Gabule committed constructive fraud by misrepresenting the property’s area and thereby obliging the heirs to reconvey the misincluded portion.
Petitioners (the heirs of Gabule) filed a Motion to Nullify the RTC decision, which on March 5, 2007, was set aside by the RTC on the ground that respondent, not being an owner, had lost any cause of action.
The Court of Appeals (CA) reversed the March 5, 2007 RTC Order, reinstating the May 10, 2006 decision on the basis that Gabule’s fraudulent act created a constructive trust in favor of the respondent, and that respondent’s possession of the property was never interrupted.
Petitioners subsequently elevated the issue through a Petition for Review on Certiorari, arguing, among other points, that the RTC decision had become final and that respondent’s appeal was barred by res judicata, as well as contending that fraud was not sufficiently proven.

Whether the RTC decision (and the subsequent order set aside on March 5, 2007) had become final and executory, thus invoking the doctrine of immutability of judgments.

The petitioners argued that once a judgment is final, it cannot be modified—even to correct factual or legal errors—and that respondent’s motions for reconsideration were mere procedural scraps that did not toll the reglementary period for appeal.

Whether the lower court’s rulings and the CA’s reversal appropriately constructed a cause of action for reconveyance based on allegations of fraud and misrepresentation.

A key point is whether fraud was clearly or convincingly established by the respondent, particularly regarding the discrepancy between the deed of sale (156.25 sq. m.) and the OCT (337 sq. m.) and whether this mismark led to the erroneous inclusion of the subject property.

Whether the doctrine of res judicata applies to bar the subsequent reconveyance action filed by the respondent, given the prior final judgment in the earlier case (Saldua v. Heirs of Felicisimo Gabule).

The issue involves ascertaining the identity of parties, subject matter, and causes of action between the earlier and the present actions.

Whether respondent, having sold part of his property and thus lost any material interest, is the real party in interest to claim reconveyance of Lot No. 2857-B-1.

The petitioners contend that respondent’s prior sale of the property deprives him of standing, rendering his claim for reconveyance devoid of cause.

Whether the proper application of the constructive trust doctrine is justified under the established facts and evidentiary record, particularly as it concerns the alleged fraudulent act of including an additional portion of land in Gabule’s title.