Case Summary (G.R. No. 210592)
Factual Antecedents
Ireneo Domingo is the registered owner of lands totaling 13,165 square meters, covered by Transfer Certificates of Title Nos. EP-82013 and EP-82015, issued on May 24, 1989. On the other hand, Regino Dela Cruz was a farmer-beneficiary of three parcels covered by different Emancipation Patents (EP). The ownership of these lands became contentious when Domingo filed a recovery of possession case against Dela Cruz on January 30, 2006, followed by two additional cases. Dela Cruz failed to respond timely, leading to a consolidated decision by the Department of Agrarian Reform Adjudication Board (DARAB) on April 25, 2006, ordering him to vacate the premises.
Filing of Case for Annulment
Without awaiting the resolution of his previous motions, Dela Cruz subsequently filed DARAB Case No. 372 for the annulment of Domingo's titles, claiming ownership based on alleged prior sale and various supporting affidavits. Domingo contested the validity of Dela Cruz’s claims, especially emphasizing forum shopping due to the ongoing cases against Dela Cruz. The DARAB's decision on September 26, 2007, reaffirmed Domingo's ownership and dismissed Dela Cruz's claims for lack of evidence.
Appeals and Rulings
Dela Cruz pursued the matter through further appeals resulting in DARAB Case No. 15566 on December 3, 2009. However, his claims of fraud and deceit regarding the issuance of the EPs were found to lack sufficient merit and were dismissed, leading to a reaffirmation of the previous decisions. In subsequent stages, the Court of Appeals (CA) addressed Dela Cruz's claims in a petition for review (CA-G.R. SP No. 114223) and ultimately dismissed the petition due to forum shopping, noting that his claims should have been interposed as counterclaims in the earlier recovery cases filed by Domingo.
Issues Presented
The essential issues laid out by Dela Cruz concern the alleged violations of forum shopping and whether the cancellation of titles could be raised as a compulsory counterclaim without violating rules against collaterally attacking titles.
Petitioners' Arguments
Dela Cruz argued that he did not engage in forum shopping as the cases involved separate issues of possession versus ownership, and emphasized that the separation was necessary to avoid a collateral attack on Domingo's established ownership. He contested the CA's ruling, asserting the legitimacy of his claims of ownership and entitlement to remediative actions.
Respondent's Counterarguments
Domingo rebutted Dela Cruz’s contentions by reaffirming that the CA's findings were correct and underscored that a pending appeal in the recovery cases would lead to res judicata, thereby barring the separate annulment case. Domingo asserted that Dela Cruz's claims coul
...continue reading
Case Syllabus (G.R. No. 210592)
Case Background
- The case revolves around the ownership and possession of agricultural land totaling 13,165 square meters located in San Miguel (Mambarao), Quezon, Nueva Ecija, registered under Transfer Certificates of Title Nos. EP-82013 and EP-82015, owned by respondent Ireneo Domingo.
- Petitioner Regino Dela Cruz was a farmer-beneficiary of three parcels of land, with claims that his rights were infringed by Domingo's titles.
- A series of legal actions began when Domingo filed a case for recovery of possession against Dela Cruz, claiming that Dela Cruz was on his land by mere tolerance.
Factual Antecedents
- On January 30, 2006, Domingo filed for recovery of possession against Dela Cruz, leading to the consolidation of three cases (DARAB Case Nos. 298, 299, and 300).
- Dela Cruz did not respond in time, resulting in a decision ordering him to vacate the land.
- Dela Cruz subsequently filed DARAB Case No. 372 to annul Domingo's titles, asserting that he had purchased the land from a previous owner, Jovita Vda. de Fernando, and that Domingo's titles were secured through fraudulent means.
Procedural History
- The DARAB dismissed Dela Cruz's case, stating he failed to prove ownership and that the lands in question were awarded to Domingo.
- Dela Cruz appealed the DARAB decision but was met with the same ruling affirming that his claims lacked merit.
- Dela Cruz file