Case Summary (G.R. No. 249434)
Key Dates and Procedural Posture
- 1978: Deed of sale (alleged) from Domingo and Emilia to Cynthia.
- 1996 onwards: TIDCORP sued Domingo; compromise resulted in conveyance of 109,234 sq.m. to TIDCORP and issuance of new titles in 2004.
- 2005: Petitioner filed collection case (RTC Manila, Civil Case No. 05-11400) against Domingo seeking payment for value of ceded portion; Domingo died and Luis substituted.
- 2008: Luis filed annulment of sale and cancellation of titles (RTC Antipolo, Civil Case No. 08-8406).
- 2014–2018: RTC Manila, CA, and Supreme Court (G.R. No. 234220) resolved collection case in favor of petitioner and Cynthia, finding the 1978 sale valid.
- 2015–2019: RTC Antipolo dismissed annulment case for litis pendentia; CA reversed and remanded; this Court granted the petition and reinstated the RTC Antipolo dismissal.
Applicable Law and Doctrines
Constitutional basis: 1987 Constitution (decision rendered in 2023).
Statutory and doctrinal authorities relied upon in the decision: Presidential Decree No. 1529 (Property Registration Decree), Section 48 (prohibiting collateral attack on a certificate of title); Rules of Court, Rule 6, Section 7 (compulsory counterclaim); Civil Code Article 1236 (reimbursement for payment for another); and established jurisprudence on litis pendentia, res judicata, collateral attack on Torrens titles, compulsory counterclaims, and forum shopping.
Factual Background Relevant to the Dispute
Domingo and Emilia purportedly sold the Antipolo property in 1978 to Cynthia for P65,000. Over the years the title was canceled and reissued in Cynthia’s name (TCT No. N-50023). Later, to settle Domingo’s obligations to TIDCORP, 109,234 sq.m. was conveyed to TIDCORP under a compromise approved by the CA; other portions were titled in Cynthia’s name. Petitioner later claimed that, under an oral agreement, Domingo owed him P120 million for the value of the portion ceded to TIDCORP; failure to pay led to the collection case. Luis maintained that the 1978 sale was simulated and that his parents were the true owners, prompting his later annulment action to cancel the titles issued in Cynthia’s name.
RTC Manila (Collection Case) – Trial Findings and Reasoning
In the collection action, the pivotal issue was whether the 1978 deed of sale to Cynthia was genuine or simulated. The RTC Manila conducted a full-blown trial, reviewed documentary and testimonial evidence, and concluded that there was insufficient proof of simulation. It relied on chronological events (mortgage annotations, cancellations, SPAs, a Letter of Guaranty, compromise agreement, deed of conveyance to TIDCORP, and decade-spanning conduct) and on the principle of the indefeasibility of Torrens titles to find the sale valid. The RTC awarded petitioner and Cynthia compensation for the portion ceded to TIDCORP. The CA and later this Court (in G.R. No. 234220) affirmed those findings, resolving the collection case against Luis.
RTC Antipolo (Annulment Case) – Motion to Dismiss and Basis
While the collection case was pending and ultimately resolved, Luis filed a separate action in RTC Antipolo to annul the 1978 sale and cancel TCT Nos. R-19952 and R-19953. Petitioner moved to dismiss Civil Case No. 08-8406 on the ground of litis pendentia, arguing that the core issue (whether the 1978 sale was simulated) had already been litigated and adjudicated in the collection case. The RTC Antipolo granted the motion to dismiss, finding the elements of litis pendentia present and emphasizing the rule against multiplicity of suits and the public policy against relitigation.
Court of Appeals’ Contrary View
The CA reversed the RTC Antipolo, holding that litis pendentia did not exist because: (a) the causes of action differed in form (collection vs. annulment) and therefore the RTC Manila’s ruling on ownership was not necessarily conclusive; (b) the parties were not identical as the opposing parties differed (Domingo/Emilia/DOMEL Corp. in the collection case versus petitioner and Cynthia as defendants in the annulment case), and Luis’s interest was then only inchoate until Domingo’s death; and (c) the situation was akin to an ejectment case where ownership determinations may be provisional for purposes of possession.
Issue Presented to the Supreme Court
Whether the annulment-of-sale and cancellation-of-title action pending in RTC Antipolo was barred by litis pendentia, given the prior adjudication in the collection case (which had reached finality), and whether the CA erred in remanding the annulment action for trial.
Legal Standard for Litis Pendentia and Its Elements
Litis pendentia exists where two actions are pending between the same parties for the same cause of action so that one is unnecessary and vexatious. The requisites are: (a) identity of parties or substantial identity/privity; (b) identity of rights asserted and reliefs prayed for (the latter founded on the same facts); and (c) identity such that judgment in one would, regardless of outcome, amount to res judicata in the other. The controlling test is whether the same evidence would sustain both actions or whether there is identity in the facts essential to both claims.
Application: Identity of Parties and Interests
The Court found substantial identity of parties. Petitioner and Cynthia were parties in both proceedings; Domingo was originally sued in the collection case but, upon his death, Luis substituted as defendant. Luis asserted in the annulment action the same ownership interests previously asserted by Domingo and Emilia. Established doctrine does not require absolute identity of party names where succession, privity, or substitution of interest exists. Consequently, the identity-of-parties element for litis pendentia was satisfied.
Application: Identity of Causes of Action and Evidence
The Court determined that the pivotal issue in both actions was the same: whether the 1978 sale to Cynthia was simulated and whether Cynthia’s Torrens title was valid. Despite differing forms of action (collection vs. annulment), the test is substantive: whether the same evidence would sustain both actions. Because the RTC Manila conducted a full trial on the question of simulation and ownership, and because that issue was essential to the judgment in the collection case (and thereafter affirmed on appeal), the identity-of-cause-of-action requirement was met. The Court rejected the CA’s analogy to ejectment: unlike ejectment’s provisional ownership determinations that stem from summary procedures, here the issue was resolved after full adversarial proceedings and appellate review, rendering the ownership determination conclusive for purposes of res judicata and litis pendentia.
Collateral Attack on Torrens Title and Compulsory Counterclaim Doctrine
Section 48 of PD No. 1529 prohibits collateral attacks on certificates of title; cancellation or annulment of a Torrens title must be sought in a direct proceeding. The Court treated Luis’s c
...continue readingCase Syllabus (G.R. No. 249434)
Parties and core subject matter
- Petitioner: Rene Manuel R. Jose (referred to as petitioner or Rene), joined by his wife Cynthia Cuyegkeng Jose (Cynthia).
- Original adverse parties: Domingo Jose and Emilia Jose (parents of petitioner and Luis); later substitution by Luis Mario Jose (Luis) upon Domingo’s death; eventual respondents in the petition are Elizabeth Quesada-Jose, for herself as heir, and as representative of co-heirs, children of deceased Luis Mario Jose.
- Central subject: controversy over ownership of an Antipolo City property (the “Antipolo property”), validity of a 1978 deed of sale to Cynthia, subsequent certificates of title (TCT Nos. N-50023; later R-19951, R-19952, R-19953), alleged simulation/fraud, claim for compensation for portion ceded to TIDCORP, and ancillary petitions for annulment of sale and cancellation of titles.
- Reliefs sought in the two principal actions: (a) a collection action for sum of money and damages with preliminary attachment (Civil Case No. 05-11400 before RTC Manila) seeking payment for value of property ceded to TIDCORP; (b) an annulment of sale and cancellation of TCT Nos. R-19952 and R-19953 (Civil Case No. 08-8406 before RTC Antipolo).
Factual background and property transactions
- The Antipolo property originally covered by TCT No. 56762 (registered in the names of Domingo and Emilia).
- On November 3, 1978, a Deed of Sale was executed in favor of Cynthia for P65,000.00; TCT No. N-50023 was later issued in Cynthia’s name (annotation history and dates provided in trial chronology).
- In 1996 TIDCORP (then Philippine Export and Foreign Loan Guarantee Corporation) sued Domingo as a solidary debtor; a compromise resulted in the ceding of 109,234 sq. m. of the Antipolo property to TIDCORP to settle Domingo’s obligations; the CA approved the compromise agreement.
- Subdivision of the Antipolo property led to cancellation of TCT No. N-50023 and issuance on January 28, 2004 of: (i) TCT No. R-19951 (109,234 sq. m.) in TIDCORP’s name; (ii) TCT No. R-19952 (104,081 sq. m.) in Cynthia’s name; and (iii) TCT No. R-19953 (19,627 sq. m.) in Cynthia’s name.
- Petitioner later demanded P120 million from Domingo as fair value for the portion ceded to TIDCORP; Domingo failed to pay. Domingo executed a Deed of Revocation on July 4, 2005 (and another Deed of Revocation dated June 13, 2005 executing revocations) claiming full ownership of the Antipolo property and asserting prior arrangements to “hide” property from creditors.
- Petitioner and Cynthia filed the collection complaint on December 1, 2005 in RTC Manila. Domingo died on December 24, 2005; Luis substituted as defendant.
Procedural history — parallel litigations and key docket numbers
- Collection case: Civil Case No. 05-11400 (docketed before RTC Manila, Branch 19); RTC Manila rendered Decision on December 22, 2014 in favor of petitioner and Cynthia directing payment by the estate of Domingo and Emilia; decision affirmed on appeal by CA in CA-G.R. CV No. 104283; Supreme Court denied petition for review in G.R. No. 234220 and later ordered entry of judgment.
- Annulment case: Civil Case No. 08-8406 filed February 13, 2008 before RTC Antipolo (annulment of sale and cancellation of TCT Nos. R-19952 and R-19953) filed by Luis on behalf of his parents; RTC Antipolo granted petitioner’s motion to dismiss on July 16, 2015 on the ground of litis pendentia; CA reversed by Decision dated June 25, 2018 in CA-G.R. CV No. 107444 and remanded the case for further proceedings; CA denied reconsideration in Resolution dated September 20, 2019.
- Petition before the Supreme Court: Petitioner filed Petition for Review on Certiorari challenging the CA’s June 25, 2018 Decision and September 20, 2019 Resolution.
RTC Manila decision (collection case) — issues, findings, and rationale
- Primary issue framed by RTC Manila: whether the 1978 Deed of Sale between Domingo and Cynthia was valid or simulated/fictitious (i.e., whether the sale was a mere ploy to hide property from TIDCORP).
- Chronological facts were carefully enumerated by RTC Manila (e.g., mortgage annotation Oct. 18, 1977; deed of sale Nov. 3, 1978; mortgage cancellation Jan. 31, 1979; issuance of TCT in Cynthia’s name Sept. 11, 1980; SPAs, compromise agreement, deed of absolute conveyance, CA approval, deeds of revocation, etc.).
- RTC Manila concluded there was no sufficient evidence to prove the 1978 sale was simulated; reasons included the early cancellation of the mortgage (suggesting separate debts), long period of title being in plaintiffs’ names, and the doctrine of indefeasibility of Torrens title.
- RTC Manila held that the sale was “a perfectly valid and enforceable sale,” and that petitioner and Cynthia were entitled to payment for the portion ceded to TIDCORP; directed the estate of Domingo and Emilia to pay P53,300,000.00 plus interest (fallo quoted).
- RTC Manila relied on Article 1236 of the Civil Code regarding reimbursement for payments made for another when resolving compensation.
- RTC Manila’s determination was reached after a full-blown trial with evidence presented by both sides; it addressed simulation allegations as integral to resolving the collection claim.
RTC Antipolo ruling in the annulment case — motion to dismiss for litis pendentia
- Petitioner filed a motion to dismiss the annulment complaint on the ground of litis pendentia, asserting that Luis’s allegations (that the 1978 sale was simulated) had already been raised and decided in the collection case.
- Luis opposed, arguing absence of litis pendentia because the Antipolo case is for reconveyance while the Manila case is for collection; he further argued RTC Antipolo was not bound by the findings of a co-equal court.
- RTC Antipolo granted petitioner’s motion to dismiss in an Order dated July 16, 2015, finding all elements of litis pendentia present:
- It emphasized that the difference in form of actions was immaterial: the test is whether the same evidence would support both causes of action.
- It underscored the public policy against vexatious multiplicity of suits and the need to avoid conflicting judgments.
Court of Appeals ruling in the annulment case — reversal and remand; reasoning
- CA Decision dated June 25, 2018 in CA-G.R. CV No. 107444 reversed RTC Antipolo’s dismissal and remanded Civil Case No. 08-8406 for further proceedings.
- CA’s principal holdings:
- There was no litis pendentia because the cases involved different causes of action: the Manila case was one for collection of money; the Antipolo case was for annulment of an allegedly simulated 1978 sale and cancellation of titles.
- RTC Manila’s ruling on the validity of the 1978 sale was not conclusive; CA likened the Manila court’s resolution of ownership to a provisional determina