Case Digest (A.M. No. RTJ-09-2171) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Felicidad Javier v. Hon. Regino T. Veridiano II and Reino Rosete (G.R. No. L-48050, October 10, 1994), petitioner Felicidad Javier applied on January 25, 1963 for a Miscellaneous Sales Application covering Lot No. 1641, Ts-308, Lower Kalaklan, Olongapo Townsite Subdivision. In December 1970 she alleged that Ben Babol had forcibly entered and seized a 200-square-meter portion of her lot, prompting her to file Civil Case No. 926 for forcible entry before the City Court of Olongapo City, Branch 4. On November 7, 1972, that court dismissed her complaint for lack of proof that the area was within her lot; the Court of First Instance of Zambales and Olongapo City, Branch 3, affirmed on April 30, 1973. Petitioner subsequently secured Original Certificate of Title No. P-3259 on December 17, 1973, for Lot No. 1641. Meanwhile, Babol sold the disputed portion to Reino Rosete, who refused petitioner’s demand to vacate. On June 29, 1977, petitioner filed Civil Case No. 2203-0 in the Court Case Digest (A.M. No. RTJ-09-2171) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Lot 1641 and Forcible Entry Case
- Jan. 25, 1963: Petitioner Felicidad Javier filed a Miscellaneous Sales Application for Lot No. 1641, Ts-308, Olongapo Townsite Subdivision, with the District Land Office, Bureau of Lands.
- Dec. 1970: Alleging forcible dispossession by Ben Babol of a 200-sqm portion, Javier filed Civil Case No. 926 for forcible entry in the City Court of Olongapo City.
- Proceedings and Finality of Forcible Entry Suit
- Nov. 7, 1972: The City Court dismissed Civil Case No. 926, holding that the Bureau of Lands considered the disputed area outside Lot 1641.
- Apr. 30, 1973: On appeal, the Court of First Instance of Zambales and Olongapo City, Br. 3, affirmed the dismissal for failure to prove the area’s inclusion within Lot 1641; decision became final and executory.
- Patent, Subsequent Sale, and Quieting of Title Suit
- Dec. 17, 1973: Petitioner obtained Miscellaneous Sales Patent No. 5548 and Original Certificate of Title No. P-3259 covering Lot 1641.
- Jun. 29, 1977: After Babol sold the disputed portion to Reino Rosete, petitioner filed Civil Case No. 2203-O in the Court of First Instance of Zambales and Olongapo City for quieting of title and recovery of possession. Rosete moved to dismiss for res judicata on Jan. 27, 1978; motion granted and reconsideration denied.
Issues:
- Whether there is identity of parties between Civil Case No. 926 (forcible entry) and Civil Case No. 2203-O (quieting of title and recovery of possession) for purposes of res judicata.
- Whether there is identity of causes of action between the two suits, given that the first is an acción interdictal (forcible entry) and the second is essentially an acción reivindicatoria (quieting of title).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)