G.R. No. 125758 - Heirs of Tuazon vs. Court of Appeals

Teresita de Mesa Reforzado was appointed as co‑special administratrix of the estate of her father, Fr. Balbino Caparas.
The estate included a 999‑square meter parcel of land located in San Juan, Metro Manila.
The property was in the possession of respondent Nazario C. Lopez and his wife, Precila Lopez.

In a probate proceeding (SP. Proc. No. B‑894) before Branch 31 of the RTC of Laguna in San Pedro, petitioner sought the issuance of a writ of possession requiring respondents to turn over the parcel.
Respondent Nazario assailed this probate court order through a petition for certiorari, which was docketed as CA‑G.R. SP No. 33118 (“Nazario C. Lopez v. Teresita de Mesa Reforzado”).
Meanwhile, petitioner also filed a separate complaint before the Pasig RTC (Civil Case No. 67043) seeking the annulment of TCT No. 5918‑R (issued on July 22, 1993) over the property and its reconveyance to Fr. Balbino’s estate.

Petitioner alleged that the property was originally covered by TCT No. 217042 in the name of Fr. Anastacio Caparas (Fr. Balbino’s brother who had predeceased him).
It was contended that one Alfonso Santos had purchased the property via a “Deed of Sale with Right of Repurchase” from Nazario, who allegedly acted as attorney‑in‑fact of Fr. Anastacio based on a Special Power of Attorney (SPA).
Petitioner further claimed that Nazario failed to repurchase the property, prompting Santos to file a complaint (Civil Case No. 408) for “Surrender and Consolidation of Title.”
Petitioner argued that Santos was a non‑existent person, and that the SPA executed by the already deceased Fr. Anastacio had automatically been revoked, rendering both the Deed of Sale with Right of Repurchase and the SPA spurious.

In the Pasig RTC, respondents raised several affirmative defenses in their Answer, including lack of jurisdiction, lack of legal capacity of the petitioner, res judicata, prescription, and absence of cause of action.
Branch 71 of the Pasig RTC denied respondents’ motion to dismiss on September 24, 1999, recognizing that the petitioner had a valid cause of action.
Respondents then filed a petition for certiorari to the Court of Appeals, which on February 2, 2001, granted their petition and dismissed petitioner’s complaint in Civil Case No. 67043.
The appellate decision was based on:

The contention that petitioner’s allegations lacked factual basis.
The claim that the issuance of TCT No. 5918‑R was merely the exercise of a ministerial duty following a final and executory decision of the Pasig RTC.
The determination that the identical issues regarding the disputed property were already involved in CA‑G.R. SP No. 33118, thus barring the current action by res judicata.
The finding that petitioner’s legal capacity was compromised due to the revocation of her appointment as co‑special administratrix (a revocation that was not yet final).

Petitioner contended that the appellate court erred in applying a superseded rule (Rule 16, Sec. 1 of the Revised Rules of Court) instead of the prevailing 1997 Rules of Civil Procedure.
She argued that the alleged repurchase transaction conflicted with Article 1491 of the Civil Code, which prohibits agents from purchasing property entrusted to them.
Petitioner maintained that despite her appointment being revoked, such revocation was not final, thereby preserving her legal capacity to continue the suit.
She further argued that as the lone surviving heir of the late Fr. Anastacio, she possessed the capacity to sue.
Regarding the earlier judgment based on a compromise agreement in Civil Case No. 408, petitioner asserted that a void judgment never acquires finality and that res judicata could not be invoked since the issues (i.e., possession versus ownership) were not identical between the two cases.

Whether the principle of res judicata applies to bar petitioner’s present complaint for annulment and reconveyance, given the existence of the earlier CA‑G.R. SP No. 33118 decision.
Whether petitioner maintained the requisite legal capacity despite the revocation of her appointment as co‑special administratrix during the pendency of respondents’ appeal.
The validity of the documents (Deed of Sale with Right of Repurchase and SPA) and the propriety of the transfer of the disputed property.

Does the principle of res judicata bar the present action for annulment of title and reconveyance of the property, considering that issues regarding its possession were already adjudicated in CA‑G.R. SP No. 33118?
Has petitioner lost her legal capacity to maintain the present action due to the revocation of her appointment as co‑special administratrix, or is such removal not yet final, thereby preserving her standing?
Are the allegations concerning the spurious nature of the Deed of Sale with Right of Repurchase and the SPA, and their implications under Article 1491 of the Civil Code, sufficient to warrant the annulment of the title issued to respondents?
Is the difference in the forms of action (estate proceedings versus action for annulment of title, reconveyance, and ownership) significant enough to prevent the application of res judicata, despite involving the same disputed property?