Case Summary (G.R. No. 211755)
Antecedent Actions
Felipe Jumuad initiated an action for reconveyance and damages against the heirs of Felicisimo Gabule, asserting that he was the owner of a lot involved in prior litigation with Severino Saldua, who claimed the same lot. In the prior case (Civil Case No. 2973), Saldua's complaint was dismissed, affirming Gabule's title over Lot No. 2857-B due to lack of credible proof of his ownership.
Details of Ownership and Transactions
In respondents' claim, Jumuad alleged that he had sold a portion of his lot to Saldua, who later sold that portion further, demonstrating a chain of transactions involving the property. Jumuad contest the inclusion of his lot in Gabule's title through alleged fraudulent misrepresentation when Gabule applied for land titling.
Initial Trial Court Decision
The Regional Trial Court (RTC) ruled in favor of Jumuad in its decision dated May 10, 2006, concluding that Gabule committed constructive fraud by including the subject lot in his title application. The RTC ordered Gabule’s heirs to reconvey the property to Jumuad, leading petitioners to file a motion claiming the judge lacked authority to render judgment post-retirement.
RTC Reversal
The RTC subsequently revisited and nullified its earlier decision in March 2007, declaring that Jumuad lacked a cause of action since he did not possess ownership or actual possession of the property. The RTC concluded that the questioned land had been public prior to titling and that Jumuad had not presented sufficient evidence to prove ownership.
Court of Appeals Ruling
The Court of Appeals (CA) reversed the RTC's ruling, reinstating the May 10, 2006 decision. The CA argued that the issuance of the Original Certificate of Title affirmed the lands' private character, and that Gabule's fraud in procuring the title created an implied trust between him and Jumuad.
Petition for Review
Petitioners sought a review, contending that the RTC decision had become final and executory, and claimed the action was barred by the principle of res judicata, asserting that Jumuad failed to establish competence and ownership to pursue the reconveyance action.
Supreme Court’s Analysis
The Supreme Court upheld the position that the RTC's decision had indeed become final and executory due to procedural lapses in Jumuad's motions for reconsideration. The ruling emphasized the immutability of judgments, barring any alterations post-finality, except under very limited exceptions which did not apply in this case.
Doctrine of Res Judicata
Determining that res judicata applied, the Court illustrated that the issues regarding ownership and entitlement to the land had already been resolved in past litigation with id
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Case Background
- The case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court by the heirs of Felicisimo Gabule (petitioners) against Felipe Jumuad and his heirs (respondents).
- The petition challenges the January 21, 2013 Decision and March 5, 2014 Resolution of the Court of Appeals, which reversed and set aside the March 5, 2007 Order of the Regional Trial Court (RTC) in Pagadian City.
- The RTC Order had previously dismissed the reconveyance and damages claim filed by Felipe Jumuad against the heirs of Felicisimo Gabule.
Antecedents
- Felipe Jumuad initiated a lawsuit for reconveyance and damages, claiming ownership over a particular lot he alleged was wrongfully included in Gabule's title.
- Prior to this case, Severino Saldua filed a similar action against the heirs of Felicisimo Gabule regarding the same property, asserting he was the legitimate owner based on fraudulent inclusion in the title.
- The RTC dismissed Saldua's complaint, affirming Gabule's title. This dismissal attained finality as Saldua did not pursue an appeal.
Prior Case: Civil Case No. 2973
- Saldua owned Lot No. 2857-B, which he claimed was fraudulently included in Gabule's title.
- The RTC found that Saldua had no remaining interest in the lot due to various transactions involving its subdivision and sale.
Present Case: Civil Case No. 3075
- Jumuad claimed that he originally owned the contested lot and that Gabule fraudulently included it in his title application.
- The claim was backed by the assertion that Jumuad had previously sold portions of the land to