G.R. No. L-10806 - Aznar vs. Sucilla

The case involves an appeal from the decision of the Court of Appeals dated January 31, 2003, which dismissed the petition of the heirs of Cornelio Miguel (petitioners) and affirmed the dismissal of the complaint in Civil Case No. 2735 brought by the petitioners against the heirs of Angel Miguel (respondents).
The dispute centers on land and the donation deed executed by the deceased donors, Cornelio Miguel and his wife, Nieves, which resulted in differing interpretations of the property donated to Angel Miguel.

Cornelio Miguel was the registered owner of a 93,844 sq.m. parcel of land in Barrio Calero, Puerto Princesa City, Palawan, covered by OCT No. S-14.
The parcel was subdivided into ten lots (designated Lots A to J). Cornelio sold nine of these lots to his children; Lot G was given to Angel Miguel, while Lot J was retained by Cornelio and his wife.
Separately, the spouses owned another property in Calero, subdivided into 19 lots and covered by OCT No. G-211.
On December 28, 1973, in a deed of donation inter vivos, Cornelio and Nieves donated two lots to Angel, one being described as LOT 2-J of Psd-146880. The technical description provided detailed boundaries and measurements, establishing that the donated property was, in fact, Lot J of Psd-146880.
Angel accepted the donation in the same instrument, which later became the subject of several disputes regarding its technical description and the true intention of the donors.

Angel filed a petition for the issuance of a new owner’s duplicate of OCT No. S-14 due to the alleged destruction of the duplicate by white ants.
The court granted the petition, noting that the title existed in the Registry’s archives, and directed the issuance of the replacement title with a memorandum stating its derivation from the destroyed one.

Cornelio filed a complaint seeking the annulment or reformation of the deed of donation on the basis that a clerical error had misdescribed the property donated. Specifically, he contended that the donation should have correctly pertained to Lot 2-J of Psd-146879 and not Lot J of Psd-146880.
The trial court dismissed the complaint on January 31, 1986 for lack of cause of action, holding that the donation was a simple donation without conditions and not subject to reformation under Article 1366 of the Civil Code.
The dismissal, once affirmed, was final and executory.

Angel applied for a certificate of title in his name over Lot J of Psd-146880. The Registrar of Deeds initially denied the application, prompting Angel to file a petition for mandamus.
The trial court, noting the finality of Civil Case No. 1185, ruled that the technical description in the deed of donation clearly referred to Lot J of Psd-146880 and ordered the issuance of the certificate in Angel’s name (TCT No. 11349).
Subsequently, the Registrar of Deeds complied, and the title was issued. Angel further subdivided Lot J and donated the resulting smaller lots to his four children.

Petitioners (heirs of Cornelio Miguel) filed a complaint for the declaration of nullity of TCT No. 11349 and the derivative titles, challenging the validity of the donation deed on the ground that the true intention was to donate Lot 2-J of Psd-146879 and not Lot J of Psd-146880.
They argued that a clerical error voided the donation, creating an implied trust where Angel held the property for their benefit.
Respondents, however, asserted that the issue had been conclusively disposed of in prior cases (Spl. Proc. No. 444, Civil Case No. 1185, and Spl. Civil Action No. 1950) and that the matter was barred by the doctrine of res judicata and the concept of conclusiveness of judgment.

Whether the prior judgments in Civil Case No. 1185 and Spl. Civil Action No. 1950 conclusively settled the identity of the donated property (Lot J of Psd-146880) and precluded the present claim for reformation or nullity of the deed of donation.
Whether the petitioners, as heirs of Cornelio, have the legal capacity to sue for the reformation or annulment of the deed of donation, considering that the right to do so is personal and intransmissible to the donors.
Whether the alleged clerical error in the deed of donation constitutes a sufficient ground to warrant reformation of the donation, notwithstanding Article 1366 of the Civil Code which excludes simple donations from reformation.
Whether the doctrine of res judicata, particularly the aspect of conclusiveness of judgment, applies given the similarity of parties and the identity of issues previously adjudicated.