Case Summary (G.R. No. 210504)
Petitioner’s Allegations
Petitioners asserted ownership of the three lots, alleged prior possession before World War II, loss of possession during the war, subsequent discovery that others occupied the parcels, and institution of earlier suits for reivindication which culminated in judgments recognizing petitioners as owners. Petitioners alleged respondents entered and occupied various portions of the lots without consent and refused demands to vacate. Petitioners maintained their rights were judicially declared in earlier accion reivindicatoria proceedings and sought recovery of possession and damages/compensation for use.
Respondents’ Defenses
Respondents pleaded long possession (more than thirty years), denied petitioners’ actual possession and title, and asserted a better right of possession based on their adverse possession or public-land claims. They argued they were not bound by prior judgments in the accion reivindicatoria because those were in personam and respondents were not parties to those suits.
Key Dates and Procedural Posture
- Complaints filed with MTCC, Surigao City: August 11, 2005 (consolidated thereafter).
- MTCC (Branch 1) Omnibus Judgment awarding possession and monthly damages/compensation to petitioners: February 25, 2011.
- RTC (Branch 30) Joint Decision affirming with modification the MTCC judgment: August 17, 2011.
- Court of Appeals Decision granting respondents’ petition and dismissing consolidated cases: July 31, 2013.
- Supreme Court petition for review under Rule 45 of the Rules of Court (constitutional framework: 1987 Philippine Constitution, applicable to decisions dated 1990 or later).
Applicable Law and Doctrinal Points
Applicable constitutional and procedural framework: the 1987 Constitution (decision date post-1990) and Rules of Court (Rule 45 for the present petition and Rule 42 for the CA proceedings). Doctrinally relevant civil-law principles and precedents cited in the record include distinctions among actions to recover possession (accion interdictal—forcible entry and unlawful detainer—accion publiciana, and accion reivindicatoria), and the character of judgments in reivindicatory actions as generally in personam but subject to recognized exceptions binding non-parties who occupy as trespassers, transferees pendente lite, sublessees, co-lessees, agents, guests, or members of the family/privy.
Nature of the Action — Characterization by the Courts
Although the complaints were captioned “Accion Publiciana and/or Recovery of Possession,” the trial and appellate courts (and the Supreme Court) determined the complaints were substantively accion reivindicatoria because petitioners sought recovery based on ownership/title rather than merely asserting a better right to possess irrespective of title. The Court reiterated the settled distinctions: accion publiciana addresses better right of possession independently of title; accion reivindicatoria seeks recovery as an incident of ownership and determines ownership.
Legal Issue Presented
Whether final and executory judgments in a prior accion reivindicatoria, which declared petitioners as owners and directed restitution of possession, bind respondents who were not parties to those prior proceedings and whether such judgments entitle petitioners to recover possession from respondents.
Court’s Analysis — In Personam Nature of Reivindicatory Judgments and Exceptions
The Court recognized the general rule that a judgment in an accion reivindicatoria is in personam: it typically binds only the parties properly impleaded and their successors in interest by title subsequent to the commencement of the action. The Court, however, applied the well-established exception: non-parties who are trespassers, squatters, agents of the defendant fraudulently occupying the property to frustrate judgment, transferees pendente lite, sublessees, co-lessees, guests or occupants with the defendant’s permission, or members of the family/privy of the defendant may be bound by such judgments. The Court concluded the CA erred in mechanically applying the in personam rule without considering whether respondents fell within these exceptions.
Application of the Exception to the Facts
Relying on the MTCC’s factual findings — which the RTC had affirmed — the Court adopted the MTCC’s characterization of respondents as mere intruders/trespassers. The MTCC found respondents occupied portions of the lots merely as places to stay, expressed intent to claim ownership only if declared public lands, had not declared the lots in their own names for taxation, and failed to pursue legal modes of a
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Case Caption, Procedural Posture and Relief Sought
- G.R. No. 210504; Decision promulgated January 24, 2018 by the Supreme Court, Second Division (Peralta, J., ponente).
- Petition for review on certiorari under Rule 45 of the Rules of Court assailing the Court of Appeals (CA), Cagayan de Oro City Decision dated July 31, 2013 in CA-G.R. SP No. 04500.
- Petitioners: Heirs of Alfonso Yusingco, represented by their attorney-in-fact Teodoro K. Yusingco.
- Respondents: Amelita Busilak, Cosca Navarro, Flavia Curayag and Lixberto (Lexberto) Castro (and originally also Reynaldo Peralta and Adriano Solamo in MTCC judgment).
- Lower court judgments involved: Municipal Trial Court in Cities (MTCC), Branch 1, Surigao City Omnibus Judgment dated February 25, 2011; Regional Trial Court (RTC), Branch 30, Surigao City Joint Decision dated August 17, 2011; Court of Appeals Decision dated July 31, 2013 setting aside the RTC Joint Decision.
- Relief sought by petitioners before the Supreme Court: reversal of the CA Decision and reinstatement of the MTCC Omnibus Judgment.
Factual Background
- On August 11, 2005, petitioners filed five separate complaints for accion publiciana and/or recovery of possession against respondents and a certain Reynaldo Peralta; the five suits were consolidated and raffled to MTCC Branch 1, Surigao City.
- Petitioners alleged ownership of three parcels: Lot Nos. 519, 520, and 1015, all located at Barangay Taft, Surigao City, inherited from predecessor-in-interest Alfonso Yusingco.
- Petitioners alleged they possessed the properties prior to and at the start of the Second World War, lost possession during the war, and, after the war, discovered occupation by several persons, prompting earlier actions for accion reivindicatoria and recovery of possession.
- While earlier ownership cases were pending, respondents purportedly entered and occupied different portions of those properties without petitioners’ knowledge or consent.
- Petitioners alleged they had to tolerate respondents’ occupation due to lack of resources and because their ownership was being disputed in earlier cases; after earlier cases were decided in petitioners’ favor, petitioners demanded respondents vacate, but respondents allegedly refused.
Respondents’ Pleadings and Defenses
- Respondents claimed continuous possession of the subject properties for more than thirty years.
- Respondents contended petitioners never actually possessed the parcels and never had title thereto; thus respondents’ claim of possession would be superior and in conflict with petitioners’ claim.
- Respondents essentially asserted rights of possession (claiming prescription or long possession) and denied petitioners’ superior title/possession.
Trial and MTCC Findings (Omnibus Judgment, Feb. 25, 2011)
- MTCC rendered judgment in favor of petitioners and ordered:
- Defendants (Flavia Curayag, Cosca Navarro, Amelita Busilak, Lexberto Castro, Reynaldo Peralta, and Adriano Solamo) and those claiming under them to vacate premises occupied and remove improvements and restore possession to plaintiffs.
- Monthly compensations awarded to specific defendants for the use of the properties occupied by them (amounts and computation dates specified for each defendant: Busilak P1,200; Navarro P2,120; Curayag P1,760; Lexberto Castro P1,500; Peralta and Solamo P2,000).
- All defendants to pay costs of suit.
- MTCC reasoning relied on prior adjudications:
- Reference made to earlier Civil Case No. 1645 decided by the Court of First Instance of Surigao Del Norte on June 8, 1979, and affirmed by the CA on August 30, 1982 (CA-G.R. No. 66508-R), which became final and executory on December 18, 1986, declaring petitioners the true and lawful co-owners of the subject properties.
- MTCC found respondents to be mere intruders/trespassers on the lots and not entitled to possession; their physical possession was not in the concept of an owner and they failed to apply for legal modes of acquiring public land if that was their contention.
- Because respondents’ entry was illegal from the beginning, they could not acquire ownership by prescription; petitioners’ judicially-declared ownership entitled them to possession against respondents’ status as squatters.
RTC Proceedings and Decision (Branch 30, Aug. 17, 2011)
- Respondents appealed the MTCC Omnibus Judgment to the RTC.
- RTC issued a Joint Decision affirming with modification the Omnibus Judgment.
- Dispositive portion: The MTCC Omnibus Judgment dated February 25, 2011 was affirmed with modification as to defendants Reynaldo Peralta and Adriano Solamo who did not file an appeal from the MTCC judgment.
CA Proceedings and Decision (CA-G.R. SP No. 04500, July 31, 2013)
- Respondents filed with the Court of Appeals a petition for review under Rule 42 of the Rules of Court assailing the RTC Joint Decision.
- CA granted respondents’ petition and set aside the RTC Joint Decision, ordering:
- The MTCC Omnibus Judgment dated February 25, 2011 in consolidated civil cases for Accion Publiciana and/or Recovery of Possession was SET ASIDE.
- The consolidated cases were DISMISSED for lack of merit.
- CA’s principal legal reasoning:
- The RTC and MTCC relied on judgments in a prior accion reivindicatoria, which is an action in personam; such judgments bind only the parties properly impleaded in that action.
- Since respondents were not parties to that prior action, they could not be bound by the prior judgments declaring petitioners as owners; hence petitioners’ present actions to recover possession on the basis of those judgment