G.R. No. 139274 - Quezon Province vs. Marte

Private respondent, Green Square Properties Corporation, acquired a vast tract of land from the estate of Don Mariano San Pedro y Esteban by means of a deed of sale dated August 14, 1996.
The property, described as consisting of 50,497 hectares, is primarily situated in General Nakar and Infanta, Quezon, with portions also in Laguna and Rizal provinces.
Initially, the land was covered by Tax Declaration No. 09-019-0094 in the name of Don Mariano San Pedro y Esteban; later, following confirmation of the sale, the declaration was cancelled and reissued in the name of Green Square.

The deed of sale indicated that the property was part of the land under Titulo de Propriedad No. 4136 dated April 29, 1894.
In a prior case, G.R. No. 106496 (Engracio San Pedro, et al. v. Court of Appeals and Republic of the Philippines, 265 SCRA 733, December 18, 1996), the Supreme Court declared Titulo de Propriedad No. 4136 null and void, ruling that no rights could be derived therefrom.
As a consequence of that decision, all lands covered by said titulo were excluded from the estate’s inventory, and any action based on it (including claims of adverse possession or ownership) was disallowed.

In July 1998, Green Square tendered payment for the real property taxes on the subject land following a notice from the Municipal Treasurer of General Nakar; however, the tender was refused by the petitioners.
Green Square subsequently filed a complaint for quieting of title and mandamus, alleging that the refusal to accept its tender of payment cast doubt on its rights and title over the property.
The complaint also sought to compel petitioners to accept the tender of payment.

On October 21, 1998, petitioners moved to dismiss Green Square’s complaint on several grounds, including that the cause of action was barred by a prior judgment or res judicata.
The Regional Trial Court of Infanta, Quezon, Branch 65, denied the motion to dismiss on March 17, 1999.
In its evaluation, the trial court noted that:

The plaintiff (Green Square) had established legal and equitable title over the subject property, including evidence of possession for over thirty years, tacked from its predecessor-in-interest.
The refusal to accept the tender of payment was deemed a cloud over title substantial enough to warrant judicial intervention.
The complaint’s cause of action was not barred by res judicata, since the controversy reportedly focused on mandamus compelling the acceptance of taxes rather than directly on title ownership.

Petitioners alleged a grave abuse of discretion on the part of the trial court amounting to lack of jurisdiction.
They contended that the trial court erred by:

Including as an issue the coverage of the land under Titulo de Propriedad No. 4136, a fact not contested by the parties.
Failing to recognize that the subject matter was already decided in G.R. No. 106496, thereby invoking res judicata.

Whether the parties had disputed that the land was covered by Titulo de Propriedad No. 4136.
Whether the filing of the complaint in Civil Case No. 329-1 was barred by the prior decision in G.R. No. 106496.

Whether the subject land’s coverage under Titulo de Propriedad No. 4136 was a disputed matter between the parties.

Petitioners argued that since private respondent’s complaint acknowledged that the property was covered by Titulo de Propriedad No. 4136, the trial court should not have treated this as a contested issue.
Private respondent countered that the issue required trial to determine the extent or effect of the coverage, though they did not deny the factual coverage.

Whether Civil Case No. 329-1 is barred by the doctrine of res judicata based on the earlier decision in G.R. No. 106496.

Petitioners maintained that the validity of Titulo de Propriedad No. 4136 had already been decided, rendering any subsequent claim based thereon redundant and barred by res judicata.
Private respondent argued that differences in the form of presentation of the claim or alternate grounds (such as adverse possession) rendered the current action distinct from the prior adjudicated matter.