Case Summary (G.R. No. L-48050)
Key Dates
- 25 January 1963: Javier’s application for Lot 1641 filed with Bureau of Lands.
- December 1970: Complaint for forcible entry (Civil Case No. 926) lodged against Babol.
- 7 November 1972: City Court dismisses forcible entry suit.
- 30 April 1973: CFI-Zambales affirms dismissal on appeal.
- 17 December 1973: Patent No. 5548 and OCT No. P-3259 issued to Javier.
- 29 June 1977: Quieting of title and recovery suit (Civil Case No. 2203-O) filed against Babol and Rosete.
- 27 January 1978: CFI-Zambales, Branch 1, grants Rosete’s motion to dismiss for res judicata.
- 10 October 1994: Supreme Court decision.
Applicable Law
- 1987 Philippine Constitution: protection of property rights and due process (Art. III, Secs. 1, 4; Art. XIII, Sec. 4).
- Rules of Court, Rule 39, Sec. 49 (b) on res judicata and successors in interest.
- Civil Code remedies for real property:
• Accion interdictal (forcible entry/detainer)
• Accion publiciana (plenary recovery of possession)
• Accion reivindicatoria (recovery of ownership, Art. 434)
Facts
- 1963–1969: Javier applies for and holds physical possession of Lot 1641 in Lower Kalaklan, Olongapo.
- December 1970: She alleges forcible dispossession by Babol of a 200 sqm portion and sues for forcible entry.
- The City Court finds the disputed portion outside Lot 1641 and dismisses her suit. CFI-Zambales affirms on appeal, holding Javier failed to prove boundaries.
- December 1973: Javier obtains patent and certificate of title for Lot 1641.
- Babol sells his interest, including the disputed portion, to Rosete.
- June 1977: Javier files a quieting-of-title and recovery of possession suit (Civil Case No. 2203-O) against Babol and Rosete.
Procedural History
- Forcible Entry Case (C.C. No. 926): Dismissed by City Court (1972); affirmed by CFI on appeal (1973).
- Quieting of Title Case (C.C. No. 2203-O): Rosete moves to dismiss on res judicata (1978); CFI grants and denies reconsideration.
- Supreme Court review via certiorari.
Issue
Does the prior final judgment in the forcible entry case bar the subsequent action for quieting of title and recovery of possession on the ground of res judicata?
Analysis – Res Judicata Requirements
The Court reiterated four requisites:
- Final judgment or order.
- Jurisdiction over subject matter.
- Judgment on the merits.
- Identity of parties, subject matter and causes of action.
Particulars not in dispute: the first three requisites and identity of subject matter.
Analysis – Identity of Parties
– Res judicata requires only substantial identity of parties or their successors in interest.
– Under Rule 39, Sec. 49 (b), the judgment is conclusive between parties “and their successors in interest by title subsequent to the commencement of the action.”
– Rosete, as purchaser pendente lite of Babol’s interest, qualifies as a successor in interest.
– Conclusion: identity of parties is established.
Analysis – Identity of Causes of Action
– Forcible entry (accion interdictal) concerns only de facto prior possession, irrespective of title.
– Quieting of title and recovery (accion reivindicatoria) concerns ownership and full rights to possess (jus utendi, jus fruendi).
– The first suit adjudicated who ha
Case Syllabus (G.R. No. L-48050)
Facts
- On 25 January 1963, petitioner Felicidad Javier filed a Miscellaneous Sales Application for Lot No. 1641, Ts-308, Olongapo Townsite Subdivision, Lower Kalaklan, Olongapo City, with the Bureau of Lands.
- In December 1970, Javier alleged forcible dispossession by Ben Babol of a roughly 200-square-meter southwest portion of Lot No. 1641.
- She claimed continuous, prior physical possession of the entire lot since 1961 and accused Babol of stealthily entering the disputed area, removing fencing and monuments, destroying plants, and constructing riprap along the river perimeter.
- After obtaining Original Certificate of Title No. P-3259 for Lot No. 1641 on 17 December 1973, Javier learned that Babol had sold the occupied portion to Reino Rosete.
- She demanded surrender of the 200 sqm portion from Rosete, who refused.
Procedural History
- December 1970: Civil Case No. 926 (forcible entry) filed before City Court of Olongapo City, Br. 4.
- 7 November 1972: City Court dismissed Case No. 926, noting the Bureau of Lands considered the area outside Lot No. 1641.
- 30 April 1973: The then Court of First Instance of Zambales and Olongapo City, Br. 3, affirmed dismissal on appeal for lack of proof that the area lay within Lot No. 1641.
- 17 December 1973: Javier obtained a patent and Original Certificate of Title No. P-3259 for Lot No. 1641.
- 29 June 1977: Civil Case No. 2203-O (quieting of title and recovery of possession with damages) filed in the Court of First Instance of Zambales and Olongapo City against Babol and Rosete.
- 27 January 1978: The trial court (Br. 1) granted Rosete’s motion to dismiss Case No. 2203-O on re