Case Digest (G.R. No. 242781)
Facts:
Superiora Locale Dell' Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc. v. Republic of the Philippines, G.R. No. 242781, June 21, 2022, the Supreme Court En Banc, Lopez, J., writing for the Court.On March 22, 2013, petitioner Superiora Locale filed an application for judicial registration (LRC No. TG-13-1841) seeking a Decree and Original Certificate of Title over Lots No. 1341-A (2,876 sq. m.) and No. 1341-B (136 sq. m.) in Amadeo Cadastre. The application alleged title acquisition by purchase (via a Deed of Extrajudicial Settlement with Absolute Sale) and asserted open, continuous, exclusive and notorious possession under a bona fide claim of ownership since June 12, 1945 or earlier; the lots were claimed to be alienable and disposable public domain and were supported by tax declarations (oldest tax entries allegedly from 1948).
The Office of the Solicitor General (OSG) opposed. For Lot No. 1341-A the OSG invoked res judicata, citing an earlier Court of Appeals decision in CA-G.R. CV No. 92767 (Mar. 28, 2012) that reversed an MCTC decision (LRC No. 2006-327) and dismissed petitioner’s prior registration application for failure to prove possession from June 12, 1945 or earlier and failure to establish alienable/disposable status. For Lot No. 1341-B the OSG argued the Regional Trial Court (RTC) lacked jurisdiction because its assessed value (Php14,140) fell below the threshold for RTC cognizance in cadastral cases.
On April 11, 2016, the RTC, Branch 18, Tagaytay City, issued an Order dismissing registration over Lot No. 1341-A on the ground of res judicata and dismissing the case over Lot No. 1341-B for lack of jurisdiction. Petitioner filed a notice of appeal; the RTC granted it. In a Decision dated April 6, 2018, the Court of Appeals (CA) in CA-G.R. CV No. 106867 affirmed the RTC, holding that res judicata barred the Lot No. 1341-A application and that the RTC had no jurisdiction over Lot No. 1341-B. The CA denied reconsideration in a Resolution dated October 23, 2018.
Petitioner brought a petition for review on certiorari to the Supreme Court (Rule 45), challe...(Pro-only)
Issues:
- Does the doctrine of res judicata bar petitioner’s application for registration over Lot No. 1341-A?
- May Republic Act No. 11573 (amending PD No. 1529, Section 14) be applied retroactively to petitioner’s pending registration application, thereby relaxing the possession and proof requirements?
- Although the RTC lacks independent jurisdiction over Lot No. 1341-B due to its assessed value, may the RTC entertain a joinder of causes of action so that Lot No. 1341-...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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