G.R. No. 242781 - Superiora Locale Dell' Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc. vs. Republic

Superiora Locale Dell' Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc. (petitioner) filed an application for registration of title over Lots No. 1341-A and 1341-B in Tagaytay City, Cavite, praying for the issuance of a Decree and Original Certificate of Title.
Petitioner claimed ownership of Lot No. 1341-A (2,876 sqm) and Lot No. 1341-B (136 sqm), supported by Tax Declarations and a Deed of Extrajudicial Settlement with Absolute Sale from previous owners.
Petitioner alleged open, continuous, exclusive, and notorious possession under a bona fide claim of ownership since June 12, 1945, or earlier.
The Office of the Solicitor General (OSG) opposed the application:

For Lot No. 1341-A, on the ground of res judicata due to a prior dismissal for failure to prove possession and alienable and disposable status of the land.
For Lot No. 1341-B, challenged the jurisdiction of the Regional Trial Court (RTC) because the lot’s assessed value was below the RTC’s jurisdictional threshold.

Lot No. 1341-A was dismissed on the ground of res judicata, as the same issue was already decided in a previous CA decision (CA-G.R. CV No. 92767).
Lot No. 1341-B was dismissed for lack of jurisdiction because its assessed value was below the threshold for RTC jurisdiction.

The Court of Appeals (CA) affirmed the RTC on April 6, 2018, and denied reconsideration on October 23, 2018, prompting this petition for review on certiorari.

The earlier CA decision (March 28, 2012) dismissed petitioner’s first application for registration due to petitioner’s failure to establish possession since June 12, 1945, and failure to prove that the land was alienable and disposable.
The CA in the present case found:

The earlier CA decision became final and on the merits.
Identity of parties, subject matter, and cause of action existed between the cases.
The RTC lacked jurisdiction over Lot No. 1341-B due to assessed value below jurisdictional threshold.

Republic Act No. 11573 was enacted and took effect on September 1, 2021, which amended Section 14 of Presidential Decree No. 1529 (Property Registration Decree):

Reduced the required period of possession under a bona fide claim of ownership from "since June 12, 1945 or earlier" to "at least twenty (20) years immediately preceding the filing of the application."
Simplified proof of alienable and disposable land by allowing certification from a designated DENR geodetic engineer on land classification to be sufficient.

RA 11573 is a curative statute intended to simplify and remove ambiguities in land registration laws and may be applied retroactively.

Whether the doctrine of res judicata applies to judicial registration proceedings of land titles, particularly in cases dismissed for insufficiency of evidence or lack of final adjudication on ownership.

Whether the RTC had jurisdiction to hear the application for registration over Lot No. 1341-B.

Whether RA No. 11573 may be applied retroactively to the pending land registration application and if petitioner can avail of the shortened possession requirement and simplified proof of alienable and disposable status.

Whether joinder of causes of action is permissible in the present case to allow consolidation of applications covering Lots No. 1341-A and 1341-B in one proceeding.