Title
Swan vs. Court of Appeals
Case
G.R. No. 97319
Decision Date
Aug 4, 1992
Dispute over PHHC lot ownership; Swans claim prior possession, Lladones hold title. Courts ruled res judicata bars Swans' annulment case, Lladones entitled to possession.

Case Digest (G.R. No. 97319)

Facts:

  • Parties Involved
    • Petitioners:
      • Godofredo T. Swan
      • German T. Swan
      • Gabriel T. Swan
      • Glenn T. Swan
    • Respondents:
      • Spouses Patrocinio Lladones and Nieves Lladones
      • Other private respondents involved in related proceedings
  • Background and Disputed Property
    • The disputed property is a People’s Homesite and Housing Corporation (PHHC) lot designated as Block 5, Lot 21 of the Bago-Bantay, Quezon City Subdivision Plan.
    • Historical Occupation and Claim:
      • In 1959, the petitioners’ parents, Atanacio B. Swan and Maria T. Swan, settled permanently in Bago Bantay, Quezon City and occupied the disputed lot.
      • The spouses Lladones moved into a nearby area (Block 5, Lot 22) in 1961.
    • Applications to Purchase the Lot:
      • Atanacio B. Swan filed an application in November 1967 to purchase the lot.
      • Around January 14, 1977, spouses Lladones filed their own application to purchase the disputed Block 5, Lot 21 after discovering that their originally occupied lot (Block 5, Lot 22) had been awarded to another family.
      • Without the Swans’ apparent knowledge, the spouses Lladones obtained TCT No. 286437 on March 26, 1982 over Block 5, Lot 21.
  • Litigation History and Proceedings
    • Civil Case Q-90-5183:
      • The Swans (petitioners) filed an action for annulment and cancellation of title against the spouses Lladones.
      • The Quezon City RTC initially did not dismiss their complaint.
      • The spouses Lladones elevated the matter to the Court of Appeals, which reversed the RTC decision on the ground that the petitioners’ proper remedy should have been a special civil action for certiorari alleging grave abuse of discretion by the NHA (successor of PHHC).
    • Related Ejectment and Forcible Entry Cases:
      • Following the issuance of TCT No. 286437, two ejectment cases were instituted by the private respondents against Maria Swan and another occupant.
      • On November 29, 1988, a decision was rendered ordering the petitioners to vacate the premises.
      • On September 14, 1989, petitioners were ejected; however, they reentered the premises later that day, prompting the filing of a forcible entry case (Civil Case No. 37-2571) by the private respondents.
      • The forcible entry case was later decided in favor of the private respondents, and petitioners appealed to the Quezon City RTC, Branch 85.
      • The appellate court eventually granted private respondents’ motion for execution pending appeal on February 10, 1992, and petitioners received a notice to vacate on March 23, 1992.
    • Petition Before the Supreme Court:
      • In G.R. No. 104554, the petitioners sought a temporary restraining order to enjoin the execution of ejectment proceedings, arguing that the disputed petition in Civil Case Q-90-5183 was affected by the prior decision in G.R. No. 97319.
      • They contended that their appeal to the Court of Appeals (in G.R. No. 97319) already resolved the contested issues regarding the annulment of the disputed lot award.
  • Additional Related Cases and Allegations
    • Other disputes over the same property or related title issues were noted, including:
      • A case filed on July 1, 1977 by Sps. Teodoro and Fortunata Laher along with Maria Swan vs. NHA, which targeted the annulment of the award of the lot.
      • A subsequent recovery of possession case (Civil Case No. Q-40957) won by Patrocinio Lladones.
    • Reference to Raymundo vs. PHHC:
      • The case was cited to illustrate that awards under the PHHC (or its successor NHA) can only be contested through a special civil action for certiorari if there is an allegation of grave abuse of discretion or lack/excess of jurisdiction.
  • Summary of the Core Dispute
    • The petitioners contest the legitimacy of the execution of the ejectment proceeding based on prior judicial determinations.
    • They argue that their complaint in Civil Case Q-90-5183, which seeks annulment of title, has been precluded by the final judgment in the earlier 1977 case (later reviewed in G.R. No. 97319) through the doctrine of res judicata.
    • They additionally challenge the proper remedy and jurisdictional grounds underlying the earlier decisions.

Issues:

  • Procedural Issues
    • Whether the petitioners’ application for a temporary restraining order (in G.R. No. 104554) to enjoin the execution of the ejectment proceedings is proper under the circumstances.
    • Whether the proper remedy in contesting the award of the disputed lot should have been a special civil action for certiorari rather than a direct action for annulment and cancellation of title.
  • Merits and Preclusive Effect
    • Whether the previous judgment in the 1977 annulment case (and its subsequent appeal reviewed in G.R. No. 97319) precludes the re-litigation of the same issues in Civil Case Q-90-5183 due to the doctrine of res judicata.
    • Whether there exists identity of parties, subject matter, and cause of action between the 1977 case and the 1990 annulment case.
  • Judicial Review of Agency Actions
    • Whether the courts have jurisdiction to review and set aside actions taken by the National Housing Authority (NHA) regarding the award of the lot.
    • Whether the decision in Raymundo vs. PHHC establishes the correct judicial approach in handling such disputes.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
Unlock Full Case Digest

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms