Case Summary (G.R. No. 233767)
Trial Court Findings
The Regional Trial Court found Corcuera never in actual possession and held his OCT tainted by fraud based on the DENR-Region III Certificate of Finality. It ruled petitioners had acquired ownership of the disputed 14,093 sqm through open, continuous, exclusive, and notorious possession since 1965. Corcuera’s complaint was dismissed for lack of merit.
Court of Appeals Reversal
The Court of Appeals held petitioners’ documentary evidence inadmissible for failure to formally offer and identify it. It deemed OCT P-7061 regularly issued and protected by the principle that registration cannot be collaterally attacked. The CA reversed the RTC, ordered petitioners to vacate, and denied their motion for reconsideration.
Parallel Nullification Proceedings
In a separate suit, petitioners successfully nullified Corcuera’s free patent and OCT for the 14,093 sqm portion. Both the RTC and the CA upheld petitioners’ ownership, and this Court denied Corcuera’s Rule 45 petition, rendering the judgment final.
Res Judicata by Conclusiveness of Judgment
The Supreme Court applied res judicata by conclusiveness, noting that the final SC resolution in the parallel case (G.R. No. 231304) conclusively determined petitioners’ ownership of the same 14,093 sqm portion. The requirements—finality, jurisdiction, on-the-merits disposition, and identity of parties and issue—were satisfied.
Determination of Better Right of Possession
Accion publiciana determines the better right to possess irrespective of title. A registered title is presumptive but may yield to superior possessory rights. Petitioners, as lawful owners by prescription of the disputed portion, had a better right of possession than Corcuera.
Prescription and Possessory Rights
The Court of Appeals’ findings, upheld in the parallel case, established that petitioners mai
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Facts of the Case
- July 12, 2006: Danilo Corcuera, through attorney-in-fact Charles Burns, Jr., filed an action for Recovery of Possession and Damages against the Heirs of Eutiquio Elliot over a parcel covered by Original Certificate of Title (OCT) No. P-7061.
- Subject land described as Lot 11122, Cad. 547-D, Calapacuan, Subic, Zambales, containing 34,264 sq. m., with market value of ₱140,850.00 and assessed value of ₱56,340.00, under Tax Declaration Nos. 006-1748 and 006-1341 A in Corcuera’s name.
- Mid-1994: Petitioners allegedly entered the parcel without consent, planted trees, claimed ownership; refused demands to vacate.
Petitioners’ Counterclaims and Defenses
- Filed administrative Protest with Petition to Annul/Cancel Free Patent No. (111-4)005010 (OCT P-7061) before DENR, raising a prejudicial question and rendering the complaint premature.
- Asserted respondent failed to comply with compulsory Katarungang Pambarangay proceedings.
- Noted annotation on OCT P-7061 showing respondent ceded a portion to Juanita Filipinas, who initiated a forcible entry suit (MTC Civil Case No. 002-06) and held her own certificate of title.
- Claimed superior right over the entire tract based on earlier possession and prescription.
Trial Court Ruling (RTC Branch 72, Olongapo City)
- Decision dated March 4, 2015 dismissed Corcuera’s complaint for lack of merit.
- Found respondent was not in possession; OCT issuance irregular and tainted by fraud (per DENR-Region III Certificate of Finality).
- Held petitioners proved open, continuous, exclusive, adverse possession since 1965 and thus acquired ownership by acquisitive prescription.
- Ruled fraud vitiates respondent’s title; absence of proof of possession at intrusion mooted recovery.