Case Summary (G.R. No. 158916)
Background of the Case
The dispute involves a parcel of land registered under Original Certificate of Title (OCT) No. S-14 in the name of Cornelio Miguel, who subdivided the land into ten smaller lots, selling nine to his children and keeping Lot J for himself and his wife, Nieves. Lot G was, however, allocated to Angel, one of Cornelio's sons. Further complicating matters, Cornelio and Nieves executed a deed of donation in 1973, transferring two lots to Angel, including Lot 2-J, which the petitioners allege was in error as they contend the intended donation pertained to Lot J of Psd-146880.
Litigation History
Over the years, several cases emerged regarding the ownership of the property donations. In 1977, Angel filed for a new owner’s duplicate of OCT No. S-14 citing the original’s destruction, which was granted, establishing his ownership of the disputed lands. Subsequently, Cornelio filed for annulment of the donation in 1977, asserting the existence of a clerical error in the deed. The court dismissed this complaint in 1986 for lack of a cause of action since reformation was not permissible for a simple donation. This decision became final and executory, preventing further challenges related to the deed of donation.
The Current Case
In the present case, Civil Case No. 2735, the petitioners sought to nullify Angel's titles, asserting that Lot J was intended for them as beneficiaries and claiming that an implied trust existed. The respondents countered by arguing that the cause of action was already settled by prior judgments concerning the ownership and had become res judicata. The trial court ruled in favor of the respondents, and the matter was escalated to the Court of Appeals.
Court of Appeals Decision
The Court of Appeals upheld the lower court's findings, emphasizing that the issue of ownership over Lot J had been litigated and settled in earlier cases. The appellate court applied the doctrine of res judicata, highlighting the conclusiveness of judgment regarding the identity of the property in question. The appellate court determined that, although the parties were indeed different in the current case, they were in privity with the respective predecessors, thus barring the petitioners from relitigating issues already definitively resolved.
Supreme Court's Ruling and Legal Principles
The Supreme Court affirmed the Court of Appeals’ decision, emphasizing the principles of res judicata and conclusiveness of judgment, which serves to prevent retrial of issues already adjudicated. The Court elaborated on the doctrines defining identity of parties, issues, and causes of action, ultimately concludi
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Case Background
- The case involves an appeal by the petitioners, the heirs of Cornelio Miguel, against the respondents, the heirs of Angel Miguel.
- The appeal is from the Decision dated January 31, 2003, of the Court of Appeals, which dismissed the petitioners' appeal and affirmed an earlier Order dated March 21, 1995, by the Regional Trial Court (RTC) of Puerto Princesa City, Palawan.
- The case revolves around a dispute over the ownership and validity of a deed of donation related to a parcel of land.
Parties Involved
- Petitioners: Heirs of Cornelio Miguel (deceased), who was the registered owner of the disputed property.
- Respondents: Heirs of Angel Miguel (deceased), brother of Cornelio Miguel, who received a property donation from Cornelio and his wife, Nieves.
Property Description
- Cornelio Miguel owned a 93,844 sq.m. parcel of land in Barrio Calero, Puerto Princesa City, covered by Original Certificate of Title (OCT) No. S-14.
- The land was subdivided into ten smaller lots, with Lot G being allocated to Angel and Lot J retained by Cornelio and Nieves.
- A second property owned by Cornelio and Nieves was also involved, designated as Lot 2 of Psd-146879.
Deed of Donation
- On December 28, 1973, Cornelio and Nieves executed a deed of donation in favor of Angel, involving two lots, one of which was Lot 2-J.
- The deed described Lot 2-J with technical boundaries and measurements, and Angel accepted the donation.
Legal Proceedings Overview
Spl. Proc. No. 444 (1977): Angel applied for a new owner’s duplicate of OCT No. S-14 after the
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