Case Summary (G.R. No. 169996)
Facts of the Case
The antecedent facts reveal that on December 26, 1983, Josefina Balinag sold a parcel of unregistered land to Pablo De Leon, which was subsequently occupied by the Iglesia ni Cristo for over ten years. The property, covered by Tax Declaration No. 5576 and assessed at twenty thousand pesos (₱20,000), was used for worship and residential purposes by the petitioners. However, on July 8, 1991, Balinag allegedly sold a portion of this same property to the respondent spouses Diaz, prompting De Leon to file a complaint for declaration of nullity of that sale on February 28, 2000.
Procedural History
The respondents filed a motion to dismiss the complaint, arguing that the case was barred by the principle of res judicata due to previous actions filed by the petitioners regarding the same property. The first action, Civil Case No. 764, was dismissed for lack of prosecution, while a subsequent action, Civil Case No. 795, was also dismissed for res judicata on February 12, 1992. The petitioners’ appeal to the Supreme Court regarding the dismissal of the second action was denied due to late filing.
Rulings of the Trial Court
The Regional Trial Court of Bontoc upheld the motion to dismiss on June 21, 2000, concluding that the current case was merely a reformatting of previous complaints to evade the effects of res judicata. The court emphasized that the evidence for Civil Case No. 1006 mirrored that of the prior actions.
Court of Appeals Decision
The Court of Appeals affirmed the dismissal on May 31, 2005, citing identical issues of law and fact between the current and previous cases. The court further maintained that no merits were established for the petitioners' arguments against res judicata and that procedural rules framed their decision.
Supreme Court Deliberation
The Supreme Court, in reviewing the petition, acknowledged the procedural dismissals of prior cases but emphasized the necessity of evaluating claims on their merits. The Court noted that the earlier cases had not reached a trial stage and were dismissed due to procedural deficiencies rather than substantive issues. The essence of the complaints differed; the first being for forcible entry and the second concerning nullity of sale.
Modification of Res Judicata
The Court determined that the principle of res judicata should yield in this instance, guided by broader cons
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Case Background
- The case arises from a petition for review on certiorari filed by petitioners Pablo Q. De Leon and Iglesia ni Cristo against respondents Josefina Balinag and spouses Emmanuel and Nellie Diaz.
- The petition challenges the decision of the Court of Appeals, which affirmed an order from the Regional Trial Court (RTC) of Bontoc, Mountain Province, dismissing Civil Case No. 1006 on the grounds of res judicata.
- The ruling of the RTC was issued on June 21, 2000, and the Court of Appeals issued its affirmation on May 31, 2005.
- The petitioners also assailed the resolution of the Court of Appeals dated October 4, 2005, which denied their motion for reconsideration.
Factual Antecedents
- On February 28, 2000, petitioners filed a complaint for declaration of nullity of a second deed of sale concerning a parcel of land against the respondents.
- The property in question was initially sold to De Leon by Balinag on December 26, 1983, encompassing 1,652 square meters.
- Petitioners claimed to have leased and subsequently possessed the property for over ten years, during which they built a house of worship and residences for their ministers.
- The key contention arose when Balinag sold part of the same property (1,162 square meters) to the Diaz spouses on July 8, 1991.
Procedural History
- Respondents filed