Case Digest (A.C. No. 6387) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The petition involves the case Gregorio Sanson and Ma. Lourdes Tirol v. Daniel M. Tapuz et al. (G.R. No. 245914, June 16, 2021). On October 5, 2009, respondents—heirs of the late Antonio Tapuz—filed Civil Case No. 8751 before the Regional Trial Court, Branch 2, Kalibo, Aklan, naming as defendants Gregorio Sanson and Ma. Lourdes Tirol, the Registrar of Deeds of Aklan, and the Administrator of the Land Registration Authority. They sought declaration of the non-existence and nullity of Transfer Certificate of Title (TCT) No. T-351383 (derivative of alleged OCT No. RO-2222 (19502)-45), recovery of possession and damages, and recognition of ownership by virtue of over fifty years’ continuous, exclusive, open, and adverse possession of parcels in Boracay island covered by various tax declarations. They alleged that petitioners’ predecessor, Ciriaco Tirol, Sr., exploited his government post to obtain titles through reconstitution of non-existent originals, resulting in technical descri Case Digest (A.C. No. 6387) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Land Claims
- Respondents, heirs of Antonio Tapuz, claim continuous, open, exclusive possession of several Boracay parcels for over 50 years under tax declarations.
- Petitioners, heirs of Ciriaco Tirol, hold Torrens titles (OCT RO-2222 and derivatives, including TCT T-35183) covering overlapping parcels, allegedly obtained by reconstitution and fraud.
- Procedural History
- October 5, 2009 – Respondents filed Civil Case No. 8751 for:
- Declaration of nullity of OCT RO-2222 and its derivative TCTs;
- Recovery of possession and damages;
- Recognition of ownership by prescription.
- Petitioners moved to dismiss on grounds of:
- Failure to implead indispensable parties;
- Prior favorable rulings (res judicata from ejectment and quieting-of-title cases);
- Forum shopping;
- Laches;
- Transferee in good faith.
- April 26, 2012 – RTC granted dismissal based on res judicata (relying on CA-G.R. SP No. 76964).
- April 24, 2017 – CA (Second Division) reversed and reinstated Civil Case No. 8751, holding no res judicata.
- February 19, 2019 – CA denied reconsideration.
- Petitioners elevated the case to the Supreme Court.
Issues:
- Does res judicata bar Civil Case No. 8751 in view of prior cases (ejectment: 201-M/7990/CA-G.R. SP No. 02859; quieting: Civ. Case 5262; petition for annulment: CA-G.R. SP No. 76964; annulment direct: Civ. Case 6585/CA-G.R. CV 03634/G.R. 230135)?
- Can laches justify the outright dismissal of Civil Case No. 8751?
- Is the action in Civil Case No. 8751 barred by prescription under the Land Registration Act?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)