Case Summary (G.R. No. 198223)
Key Dates and Procedural Posture
Material dates and events include: deed of sale (April 10, 1978); affidavit of adverse claim annotated on OCT (April 11, 1978); earlier litigation (Civil Case No. 2410) decided by RTC on November 21, 2000 and affirmed by the Court of Appeals on July 8, 2003 with denial of certiorari on February 23, 2004 (entry of judgment April 22, 2004); petitioners’ complaint filed in RTC Branch 8 on February 15, 2005 (Civil Case No. 2046-05); RTC interlocutory Order denying respondents’ special and affirmative defenses (March 6, 2006) and denial of motion for reconsideration (February 29, 2008); respondents’ petition for certiorari to the Court of Appeals (filed June 10, 2008); CA decision granting certiorari and dismissing the complaint (July 2, 2010) with denial of reconsideration (July 27, 2011); Supreme Court judgment affirming the CA (February 18, 2015).
Applicable Law and Authorities
Governing legal framework: 1987 Philippine Constitution (applicable to this decision dated 2015), the Rules of Court (notably Section 1, Rule 41 on appealability), Civil Code Article 1144(1) (prescription for actions upon written contracts), and settled doctrines on finality, interlocutory orders, res judicata, and prescription. Controlling jurisprudence cited in the decision includes Denso (Phils.), Inc. v. IAC (on final vs. interlocutory orders), Investment, Inc. v. Court of Appeals (on court’s control over interlocutory orders), Ley Construction and related cases, Firestone Ceramics, Antonio, Swan, and Church Assistance Program, among others referenced in the record.
Factual Background (as pleaded by petitioners and responses)
Petitioners allege Timbang received the subject lot as dowry during her marriage to Cota, that title (OCT No. RP-355) was issued in the spouses’ names, and thereafter Timbang and her daughters remained in possession. They assert Cota later executed a deed of sale (April 10, 1978) conveying the property to respondents without their knowledge or consent; petitioners characterize that sale as void because (they claim) Cota was not the owner or had no right to alienate the property. Respondents deny petitioners’ claims, invoke the finality of the prior litigation (Civil Case No. 2410) upholding the validity of the 1978 sale, and plead defenses including lack of cause of action, statute of frauds, prescription, estoppel/laches, and the rule on judicial stability/non-interference.
RTC Proceedings and Interlocutory Orders
The RTC (Branch 8) issued an Order on March 6, 2006 denying respondents’ special and affirmative defenses as matters to be decided at trial and directing pre-trial. Respondents filed a manifestation and moved for extension of time to file a motion for reconsideration; the RTC later denied the motion for reconsideration (February 29, 2008). The trial court’s March 6, 2006 Order was interlocutory in character because it did not dispose of the case on the merits but merely denied defenses as premature, leaving the case to proceed to trial.
Court of Appeals Ruling
The Court of Appeals granted respondents’ petition for certiorari, set aside the RTC’s interlocutory orders (March 6, 2006 and February 29, 2008), and ordered dismissal of the complaint. The CA concluded that the RTC had unduly disregarded the prior final decision in Civil Case No. 2410 — which had determined ownership and lawful possession in favor of Cota and the purchasers — and that recognizing petitioners’ claims would produce relitigation contrary to res judicata. The CA also found the action prescribed, noting registration/annotation of an affidavit of adverse claim in 1978 as the relevant notice starting the prescriptive period.
Supreme Court’s Analysis — Appealability and Timeliness of Certiorari
The Supreme Court affirmed the CA’s procedural conclusions. It emphasized the distinction between final judgments and interlocutory orders (citing Denso), explaining that the RTC’s March 6, 2006 Order was interlocutory (it did not finally dispose of the case) and therefore ordinarily not appealable except when attacked as part of a final judgment; interlocutory orders remain subject to the trial court’s inherent power to modify or rescind and are not constrained by the 15-day appeal period applicable to final orders. Hence respondents’ petition for certiorari to the CA was timely, and the RTC’s acceptance of a motion for extension of time to move for reconsideration did not render the interlocutory order final and unassailable.
Supreme Court’s Analysis — Res Judicata and Privity
On the merits, the Court found res judicata applicable. It reiterated the requisites for res judicata: (1) the prior judgment must be final; (2) the rendering court must have had jurisdiction of the subject matter and parties; (3) the decision must be on the merits; and (4) identity of parties, subject matter, and causes of action between the two cases. The Court recognized that the RTC, Branch 9, had jurisdiction and rendered a final, on-the-merits judgment in Civil Case No. 2410 (affirmed by the CA and with entry of judgment). The Supreme Court treated petitioners as in privity with their grandparents (Cota and Timbang) with respect to the property they claim by inheritance; thus petitioners are within the circle of persons precluded from relitigating issues already adjudicated. The prior judgment had resolved Cota’s ownership and the validity of the 1978 deed of sale; re-litigation of those matters in the instant suit would be inconsistent with the final adjudication, satisfying the test for res judicata (bar by prior judgment).
Supreme Court’s Analysis — Identity of Cause of Action and Inconsistency Test
The Court applied the “inconsistency” test for identity of cause
...continue readingCase Syllabus (G.R. No. 198223)
Procedural and Docket Identifiers
- Supreme Court: G.R. No. 198223, Decision dated February 18, 2015; Notice of Judgment received March 23, 2015 (Decision penned by Justice Peralta; concurrence by Justices Velasco, Jr., Del Castillo, Villarama, Jr., and Reyes; designated Acting Member Villarama, Jr., in lieu of Justice Jardeleza per Special Order No. 1934).
- Petition below: Petition for review on certiorari from Court of Appeals Decision dated July 2, 2010 in CA-G.R. SP No. 02376-MIN and CA Resolution dated July 27, 2011 denying reconsideration.
- Trial court docket: Complaint filed February 15, 2005, docketed Civil Case No. 2046-05 (raffled to Branch 8) before the Regional Trial Court (RTC), Lanao del Sur, Marawi City.
- Earlier litigation: Civil Case No. 2410 (RTC Lanao del Sur, Branch 9) — Decision dated November 21, 2000; affirmed by the Court of Appeals July 8, 2003; denial of petition for review on certiorari in G.R. No. 161438 on February 23, 2004; Entry of Judgment April 22, 2004.
Facts of the Case
- Subject property:
- A parcel of land located at Madaya, Marawi City described as having an area of 157,738 square meters.
- Said parcel is covered by Original Certificate of Title (OCT) No. RP-355 and Homestead Patent No. 47201 (referred to in the record as the "subject lot").
- Ownership lineage and possession:
- Petitioners claim ownership pro indiviso and lawful possession by inheritance from their deceased grandmother, Timbang Daromimbang Dimaampao ("Timbang"), who, they allege, was the true and exclusive owner and lawful possessor of the subject lot.
- Petitioners allege that Cota Dimaampao ("Cota") and Timbang were married under Muslim rites and that the subject lot was among the dowries given by Cota to Timbang.
- During the marriage the spouses applied for registration and titling; the homestead application was approved and OCT No. RP-355 was issued in their names.
- After divorce between Cota and Timbang, Timbang and their two daughters allegedly continued possession and ownership of the subject land; upon Timbang's death, her daughters (and later their heirs, petitioners) succeeded in possession and ownership.
- Alleged post-title transactions:
- Petitioners allege that on April 10, 1978, without their knowledge or that of predecessors, Cota executed a deed of sale in favor of respondents involving the subject land.
- Petitioners assert respondents bought in bad faith because petitioners (and predecessors) were in actual possession in the concept of owners at the time of sale.
- Petitioners claim respondents have never occupied any portion of the subject land despite the deed of sale.
- Related transactions and prior case:
- Petitioners allege that Cota allegedly sold the subject land to the late Sheik Pangandaman Daromimbang (Timbang's brother), who then donated the same to his daughter and son-in-law; those deeds of sale and donation were later annulled by RTC Lanao del Sur, Branch 9, in Civil Case No. 2410.
- Petitioners state they were not impleaded as parties in Civil Case No. 2410 even though they were in possession of the land; the RTC decision in Civil Case No. 2410 was affirmed by the Court of Appeals and became final, which petitioners say cast a cloud on their title.
Petitioners’ Prayer and Trial Court Complaint
- Reliefs sought by petitioners in Civil Case No. 2046-05:
- Declaration that the Deed of Sale dated April 10, 1978 between Cota and respondents is null and void.
- Quieting of title in petitioners' favor and declaration that petitioners are the rightful owners and lawful possessors of the subject land.
- Damages against respondents.
- Core allegations supporting the prayer:
- Ownership and possession derived by inheritance from Timbang.
- Dowry/donation or conjugal property theories to show Cota lacked authority to alienate the property.
- Lack of knowledge by petitioners of the 1978 sale at time of its execution.
Respondents’ Answer and Defenses
- Denials and alternative contentions:
- Respondents denied petitioners' claim of ownership and possession, asserting that respondents have owned and possessed the property since 1978.
- Respondents asserted that the validity of the April 10, 1978 Deed of Sale had already been upheld by the RTC in Civil Case No. 2410 (Cota Dimaampao, et al. v. Sheik Pangandaman Daromimbang, et al.) and that case had attained finality.
- Special and affirmative defenses interposed:
- Petitioners have no cause of action because the claim of dowry or donation is belied by issuance of OCT No. RP-335 in Cota's name.
- Petitioners' alleged dowry/donation not supported by written agreement and is barred by the Statute of Frauds.
- Claims barred by prescription, estoppel, or laches.
- Complaint violates rule on judicial stability or non-interference due to prior final adjudication in Civil Case No. 2410.
RTC Orders and Pre-trial Proceedings
- March 6, 2006 RTC Order (per Judge Santos B. Adiong):
- Dispositive portion: denied respondents' Special and Affirmative Defenses "for lack of merit" as matters of evidence to be properly ventilated at trial; ordered parties to submit pre-trial briefs and set pre-trial for April 6, 2006.
- Respondents’ reaction to RTC Order:
- Respondents filed a Manifestation on May 2, 2006 stating they received the March 6, 2006 Order on April 17, 2006 and moved for time to file a motion for reconsideration and to defer pre-trial proceedings.
- Motion for Reconsideration filed May 17, 2006.
- Motion for Reconsideration denied by the RTC in an Order dated February 29, 2008 (per Judge Jacob T. Malik).
Petition for Certiorari to the Court of Appeals and CA Ruling
- Filing and procedural posture:
- On June 6, 2008 respondents filed a petition for certiorari with prayer for a preliminary injunction before the Court of Appeals, Cagayan de Oro City.
- Court of Appeals Decision dated July 2, 2010 (dispositive excerpt quoted in record):
- "FOR THESE REASONS, the writ of certiorari is GRANTED. The challenged Orders of the respondent court, dated March 6, 2006 and February 29, 2008, respectively, are SET ASIDE, and another Resolution/Order will be entered in Civil Case No. 2046-05 dismissing the Complaint."
- CA rationale summarized in the decision:
- The RTC unduly disregarded the decision in Civil Case No. 2410 which had already attained finality; that prior case had determined that the subject land was the same property declared to be owned and lawfully possessed by Cota and that granting petitioners' demand would lead to unending litigation.
- Res judicata applied—prior final judgment on merits barred relitigation.
- Petitioners’ action had prescribed: petitioners waited more than 26 years (sale registered/annotated April 11, 1978), and suit filed only in 2005.
- CA factual findings relied upon (from Civil Case No. 2410 and its appellate affirmance):
- Prior findings that Cota was the owner and could validly convey the subject land to respondents.
- The