Case Digest (G.R. No. 242781)
Facts:
- The petitioner is Superiora Locale Dell'Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc.
- The respondent is the Republic of the Philippines.
- On March 22, 2013, Superiora Locale applied for the registration of title over two lots: Lot No. 1341-A (2,876 sq. meters) and Lot No. 1341-B (136 sq. meters) in Amadeo Cadastre, Cavite.
- Superiora Locale claimed absolute ownership, supported by tax declarations and a Deed of Extrajudicial Settlement with Absolute Sale.
- The petitioner asserted open, continuous, exclusive, and notorious possession since June 12, 1945, or earlier.
- The Office of the Solicitor General opposed the application, citing res judicata due to a prior dismissal by the Court of Appeals (CA) and lack of jurisdiction for Lot No. 1341-B.
- The Regional Trial Court (RTC) dismissed the application on April 11, 2016, citing res judicata for Lot No. 1341-A and lack of jurisdiction for Lot No. 1341-B.
- Superiora Locale's appeal was affirmed by the CA on April 6, 2018, and again on October 23, 2018, leading to the current petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Supreme Court granted the petition, ruling that res judicata does not apply to registration proceedings.
- The Court reversed the decisions of ...(Unlock)
Ratio:
- The Supreme Court stated that res judicata is not applicable in registration proceedings as there is no conclusive adjudication of rights.
- A judgment dismissing a land registration application does not constitute res judicata, especially when based on insufficient evidence and not determining ownership.
- Previous jurisprudence indicates that dismissals without a hearing or for lack of evidence do not create contentious issues necessary for res judicata.
- The enactment of Republic Act No. 11573 amended land registr...continue reading
Case Digest (G.R. No. 242781)
Facts:
The case involves Superiora Locale Dell'Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc. (hereinafter referred to as "Superiora Locale") as the petitioner and the Republic of the Philippines as the respondent. The events leading to this case began on March 22, 2013, when Superiora Locale filed an application for the registration of title over two lots, specifically Lots No. 1341-A and No. 1341-B, located in the Amadeo Cadastre, Cavite. Superiora Locale claimed to be the absolute owner of these lots, asserting that Lot No. 1341-A has an area of 2,876 square meters and Lot No. 1341-B has an area of 136 square meters. The lots were declared in its name and covered by respective tax declarations. Superiora Locale contended that it acquired the properties through a Deed of Extrajudicial Settlement with Absolute Sale from several individuals, and claimed to have been in open, continuous, exclusive, and notorious possession of the lots since June 12, 1945, or earlier.
The Office of the Solicitor General (OSG) opposed the application, arguing that the application for Lot No. 1341-A was barred by the principle of res judicata, as a previous decision by the Court of Appeals (CA) in CA-G.R. CV No. 92767 had already dismissed Superiora Locale's earlier application for registration due to failure to prove possession since June 12, 1945, and that Lot No. 1341-B was below the jurisdictional amount for the Regional Trial Court (RTC). The RTC dis...