Case Summary (G.R. No. 245914)
Petitioners and Respondents
Petitioners: Gregorio Sanson and Ma. Lourdes Tirol (transferees in good faith under TCT T-35183 derived from TCT T-27086).
Respondents: Heirs of Antonio Tapuz (claiming continuous, open, exclusive possession of several Boracay parcels for over fifty years) plus two Land Registration Authority defendants.
Key Dates
Complaint filed: October 5, 2009.
Trial court motion‐to‐dismiss order: April 26, 2012.
Court of Appeals reversal: April 24, 2017; denial of reconsideration: February 19, 2019.
Supreme Court decision: June 16, 2021.
Applicable Law
1987 Philippine Constitution (decision post‐1990).
Land Registration Act (Act No. 496), Section 38 (one-year bar to attack registration).
Torrens system statutory safeguards (PD 1529, Section 48).
Rules of Civil Procedure, Rule 70, Sections 16–18 (forcible entry and detainer limits) and Rule 44, Section 13 (brief requirements).
Civil Code provisions on res judicata and prescription.
Antecedent Proceedings
Respondents sued for nullity of OCT RO-2222(19502) and derived TCTs, recovery of possession, and damages—alleging petitioners’ predecessors secured spurious reconstituted titles that encroached on Tapuz lands. Petitioners counterclaimed to dismiss for failure to implead indispensable heirs of Ciriaco Tirol and invoked res judicata from several prior cases.
Trial Court Decision
The Regional Trial Court, Kalibo, granted petitioners’ motion to dismiss, finding res judicata in earlier rulings (ejectment, quieting of title, Court of Appeals decision upholding OCT validity). It held that issues and parties’ interests were sufficiently identical under Rule 39, Section 47, and denied reconsideration.
Court of Appeals Decision
On appeal, the Court of Appeals vacated the dismissal: it found no identity of parties or causes of action between Civil Case No. 8751 and prior cases, especially distinguishing an original petition for annulment of judgment (CA-G.R. SP No. 76964) from a direct suit to cancel titles. It reinstated the complaint and remanded for trial.
Res Judicata Doctrine
Under 1997 Rules, res judicata bars relitigation when a prior final, on-the-merits judgment involves the same parties (or their successors), subject matter, and cause of action (claim preclusion) or binds parties on matters decided or that could have been raised (issue preclusion).
Precedent Analysis: Ejectment Cases
Civil Case No. 201-M (MCTC), Civil Case No. 7990 (RTC), CA-G.R. SP No. 02859 (CA): these involved forcible entry and detainer. Although petitioners prevailed on possession, such judgments are conclusive only as to de facto possession—not ownership or title—and thus cannot bar subsequent actions directly challenging title (Rule 70, Sections 16–18).
Precedent Analysis: Quieting Title Case
Civil Case No. 5262 sought quieting of title in favor of Ciriaco’s heirs. Its May 7, 1999 decision on merits became final when no appeal followed. Although subject matter and cause of action align with Civil Case No. 8751, there is no privity between the heirs of Ciriaco in Case No. 5262 and the Tapuz heirs in Case No. 8751; thus the fourth element of res judicata (identity of parties or interests) fails.
Precedent Analysis: Annulment of Judgment Case
CA-G.R. SP No. 76964 was an original petition to annul the quieting decision in Case No. 5262. Its subject matter was the May 7, 1999 judgment itself—not the validity of OCT RO-2222(19502). Any reference to title validity was obiter dicta. Lack of identity in parties and causes of action precludes res judicata.
Precedent Analysis: Prior Possession Case
Civil Case No. 6585 (RTC), CA-G.R. CV No. 03634 (CA), and G.R. No. 230135 (SC) involved Tapuz heirs’ suit for annulment of title and recovery of possession—identical claims and parties to Civil Case No. 8751. However, the RTC dismissed for lack of jurisdiction over indispensable heirs; the Court of Appeals and Supreme Court affirmed that dismissal was not on the merits. Absence of jurisdiction and absence of a merits disposition negate res judicata.
Laches Doctrine
Laches requires proof of (1) complainant’s delay after
...continue readingCase Syllabus (G.R. No. 245914)
Facts and Antecedents
- Antonio Tapuz, native of Malay, Aklan, possessed several parcels of land openly, exclusively, and adversely under tax declarations Nos. 1320, 4060, 1454, 3014, and 3020 for over 50 years.
- Antonio’s heirs maintained possession after his death, believing occupation alone conferred ownership.
- Ciriaco Tirol Sr., a former government official, allegedly abused his access to records to procure reconstituted titles (TCTs No. 27083–27086 and T-2627-48) over lands overlapping Antonio’s holdings.
- The underlying OCT RO-2222(19502) was void on its face due to multiple defects:
• It covered three noncontiguous parcels in different areas yet described as one.
• Misidentified Barrio Balabag’s location.
• Bore impossible issuance dates and transcription inconsistencies. - The disputed lands were later reserved for tourism under Proclamation No. 1801 (Nov. 10, 1988).
- Respondents sought: nullity of OCT RO-2222(19502) and derivative TCTs; recovery of possession; damages (daño emergente ≥ ₱500,000); recognition of ownership by prescription.
Procedural History
- Oct. 5, 2009: Complaint filed in RTC Kalibo (Civil Case No. 8751).
- Petitioners moved to dismiss for failure to implead indispensable parties, res judicata, and other defenses; trial court granted (Apr. 26, 2012) and denied reconsideration (Aug. 9, 2012).
- Court of Appeals (CA) initially dismissed respondents’ appeal for technical non-compliance (Jan. 29, 2015), then granted reconsideration and reinstated (Apr. 22, 2016).
- Petitioners filed appellee’s brief; CA reversed trial court and remanded (Apr. 24, 2017), holding no res judicata; denied reconsideration (Feb. 19, 2019).
- Petitioners elevated to SC via G.R. No. 245914, assailing CA’s reversal and urging res judicata based on prior cases, laches, and prescription.
Issues
- Whethe