Case Summary (G.R. No. 245914)
Facts and Nature of the Controversy
Respondents alleged that their predecessor-in-interest, Antonio Tapuz, had continuous, exclusive, adverse, and open possession of several parcels in Boracay (covered by specific tax declarations) for more than fifty years. They asserted that petitioners’ predecessor, Ciriaco Tirol, Sr., obtained Transfer Certificates of Title (TCTs) derived from an Original Certificate of Title (OCT RO-2222(19502)) through improper reconstitution and that these titled parcels encroached upon lands possessed by Antonio. Respondents sought annulment of OCT RO-2222(19502) and its derivative titles, recovery of possession and damages, and recognition of ownership by prescription based on adverse possession exceeding fifty years. They also alleged the lands were reserved for tourism under Proclamation No. 1801.
Procedural Posture and Claims in the Trial Court
Respondents filed Civil Case No. 8751 in RTC Branch 2, Kalibo, impleading the Registrar of Deeds and the LRA Administrator. Petitioners answered, raising defenses including failure to implead indispensable parties, res judicata, prior favorable rulings in ejectment actions, laches and prescription, and that they were transferees in good faith for value under TCT T-35183. The LRA, through the Office of the Solicitor General, argued that respondents could not acquire ownership by prescription absent a declaration that the land was alienable and disposable.
Trial Court Ruling and Basis for Dismissal
By order dated April 26, 2012, the trial court granted petitioners’ motion to dismiss Civil Case No. 8751 on the ground of res judicata. The court relied on prior related litigation, especially Civil Case No. 5262 and the Court of Appeals’ decision in CA-G.R. SP No. 76964, which had upheld the validity of OCT RO-2222(19502) and effectively declared the title incontestable. The trial court found identity of subject matter and causes and declined to require absolute identity of parties, noting identity of interests sufficed.
Court of Appeals’ Disposition and Reasoning
On appeal, the Court of Appeals reversed the trial court, vacated the dismissal order, and reinstated Civil Case No. 8751. The CA held that CA-G.R. SP No. 76964 was not res judicata to Civil Case No. 8751 because the requisite twin elements—identity of parties and identity of causes of action—were absent. The CA characterized CA-G.R. SP No. 76964 as an original petition for annulment of the judgment in Civil Case No. 5262, not a direct appeal resolving the title’s validity; any commentary on the title’s validity in that petition was at most obiter dictum. Thus, the CA concluded Civil Case No. 8751 could proceed.
Issues Presented to the Supreme Court
The primary issue before the Court was whether Civil Case No. 8751 was barred by res judicata, laches, or prescription. Subsidiary questions concerned the applicability of prior related cases (Civil Case No. 201-M / Civil Case No. 7990 / CA-G.R. SP No. 02859; Civil Case No. 5262; CA-G.R. SP No. 76964; Civil Case No. 6585 / CA-G.R. CV No. 03634 / G.R. No. 230135) as preclusive judgments or bar to the present suit.
Doctrine and Elements of Res Judicata Applied
The Court reiterated that res judicata encompasses claim preclusion (bar by prior judgment) and issue preclusion (collateral estoppel). The elements are: (1) final judgment; (2) rendered by a court having jurisdiction over subject matter and parties; (3) disposition on the merits; and (4) identity of parties, subject matter and causes of action (or, alternately, identity of parties and subject matter for conclusiveness of judgment on matters actually decided or that could have been raised). The Court emphasized that absolute identity of parties is not always required where there is community of interest between parties in the different actions.
Analysis of Prior Ejectment and Quieting Actions (Res Judicata Contentions)
- Civil Case No. 201-M / Civil Case No. 7990 / CA-G.R. SP No. 02859 (ejectment/forcible entry): The Court held that even if finality existed, ejectment judgments are conclusive only as to possession (possession de facto) and not binding on title or ownership; Sections 16 and 18, Rule 70, Rules of Court preclude using ejectment judgments as res judicata on ownership. Therefore, these prior ejectment rulings cannot bar an action specifically addressing title.
- Civil Case No. 5262 (quieting of title): This action produced a judgment on the merits in favor of the plaintiffs claiming title derived from OCT RO-2222(19502). The Court found that Civil Case No. 5262 satisfied the first three requisites of res judicata (finality, jurisdiction, merits). However, the Court concluded there was no identity of parties or even identity of interests between Civil Case No. 5262 (involving heirs of different individuals, surnames and asserted interests) and Civil Case No. 8751 (instituted by heirs of Antonio). Thus, res judicata could not be predicated on Civil Case No. 5262 against Civil Case No. 8751.
Analysis of CA-G.R. SP No. 76964 (Annulment of Judgment) and Its Preclusive Effect
The Court explained CA-G.R. SP No. 76964 was a petition for annulment of a judgment (the May 7, 1999 decision in Civil Case No. 5262) and did not directly adjudicate the validity of OCT RO-2222(19502) in a proceeding expressly instituted for that purpose. The cause and subject matter of the petition (annulment of a prior judgment) differ from an action for nullity of title; any discussion on the OCT’s validity in the annulment petition was obiter dictum and cannot serve as a bar under res judicata. Moreover, identity of parties and identity of interests between the petition for annulment and Civil Case No. 8751 were not established.
Analysis of Civil Case No. 6585 / CA-G.R. CV No. 03634 / G.R. No. 230135 and Preclusion
Civil Case No. 6585 was a prior action by heirs of Antonio that directly assailed OCT RO-2222(19502) and its derivative titles—thus sharing identity of subject matter and cause of action with Civil Case No. 8751. The Court noted that CA-G.R. CV No. 03634 and G.R. No. 230135 affirmed dismissal of Civil Case No. 6585; the Supreme Court’s ruling in G.R. No. 230135 became final on December 11, 2017. Notwithstanding identity of cause and subject matter and of interests, the Court found the dismissal of Civil Case No. 6585 was not a judgment on the merits because the courts below dismissed for lack of jurisdiction over indispensable parties and on prescription/laches grounds. A dismissal for lack of jurisdiction over indispensable parties renders subsequent proceedings null and void to the extent jurisdiction was not acquired; such disposition is not a merits adjudication capable of operating as res judicata on the merits in a later action. Therefore, although related, the prior dismissal did not supply the second and third res judicata requisites necessary to bar Civil Case No. 8751 via claim preclusion.
Laches: Standard and Application
The Court reiterated the elements and nature of laches: failure t
...continue readingCase Syllabus (G.R. No. 245914)
The Case — Nature of Petition and Relief Sought
- Petition for discretionary appellate review assailing the Court of Appeals dispositions in CA-G.R. CV No. 05034:
- Decision dated April 24, 2017 reversing the trial court's April 26, 2012 Order dismissing Civil Case No. 8751 on ground of res judicata.
- Resolution dated February 19, 2019 denying reconsideration.
- Petitioners seek reinstatement of the trial court’s dismissal of Civil Case No. 8751.
- Relief ultimately sought in lower suit (Civil Case No. 8751) by respondents included:
- Declaration of non-existence and/or nullity of OCT RO-2222(19502) and all Transfer Certificates of Title (TCTs) derived therefrom (including but not limited to TCTs T-27083, T-27084, T-27085, T-27086, T-2627-48 and T-35183).
- Recovery of possession and damages.
- Recognition of lawful ownership by virtue of continuous, open and exclusive possession for more than fifty (50) years.
- Monetary and other damages (daños emergente of not less than P500,000.00; P200,000 moral; P50,000 exemplary; P100,000 attorney's fees; and other equitable reliefs).
Parties and Their Allegations
- Complainants in Civil Case No. 8751 (respondents here): heirs of the late Antonio Tapuz (Antonio).
- Alleged continuous, exclusive, adverse and open occupation and possession of several parcels for more than fifty (50) years.
- Parcels covered by Tax Declarations Nos. 1320, 4060, 1454, 3014 and 3020.
- Claimed belief by Antonio that possession alone conferred ownership; later learned of government prohibition on titling Boracay lands except for indigenous tribes and occupant tillers (Presidential Proclamation No. 1801 cited as reservation for tourism).
- Asserted that petitioners’ predecessor-in-interest, late Ciriaco Tirol, Sr., obtained TCTs through reconstitution and misuse of position; alleged specific defects in OCT RO-2222(19502).
- Defendants in Civil Case No. 8751 (petitioners here): Gregorio Sanson and Ma. Lourdes Tirol, owners under TCT T-35183 (derived from TCT T-27086 according to their claim).
- Defended the validity of OCT RO-2222(19502) and derivative TCTs.
- Asserted transferee in good faith and for value as to TCT T-35183.
- Raised defenses and grounds to dismiss: failure to implead indispensable parties, prior litigation/res judicata, laches, prescription, forum shopping, and lack of sufficient documentary attachments by complainants.
- Other impleaded parties below: Registrar of Deeds of Aklan and Administrator of the Land Registration Authority (LRA) as indispensable/necessary parties.
Property Titles, Specific Instruments and Alleged Irregularities
- Key titles and instruments alleged in complaint:
- Original Certificate of Title (OCT) RO-2222(19502) sometimes referenced as OCT RO-2222(19502)-45 or OCT No. R0-2222 (19502)-45.
- Transfer Certificates of Title derived from OCT RO-2222(19502): TCTs T-27083, T-27084, T-27085, T-27086, T-2627-48, and derivative TCT T-35183 (petitioners’ title).
- Alleged defects in OCT RO-2222(19502) described by respondents:
- Technical description purportedly covered three parcels in three different areas (Portion of Lot 1 in Ibajay Aklan - 1,593 sqm; Portion of Lot 29 in Balabag, Buruanga - 4,694 sqm; Portion of Lot 30 in Balabag, Buruanga - 606,798 sqm).
- Use of incorrect municipal reference (title referred to Barrio Balabag in Buruanga whereas Barrio Balabag is actually located in Malay; properties were in Boracay island, Town of Malay).
- When heirs partitioned, covered area increased and encroached on Antonio’s holdings.
- Alleged issuance by "Republic of the Philippines, Court of First Instance of Capiz" on July 25, 1943—reputedly invalid given historical context and inconsistency with alleged transcription date of August 7, 1933.
- Respondents contended reconstitution timing and factual inconsistencies made OCT RO-2222(19502) void or spurious.
Procedural Posture — Lower Court Filings and Motions
- Complaint filed October 5, 2009; case raffled to RTC Branch 2, Kalibo as Civil Case No. 8751.
- Petitioners filed answer with compulsory counterclaim and motion to dismiss raising:
- Failure to implead indispensable parties (argued complaint should have been filed against all heirs of Ciriaco if title nullity sought).
- Prior rulings upholding OCT RO-2222(19502) (citing Civil Case No. 201-M, Civil Case No. 7990, CA-G.R. SP No. 02859; CA-G.R. SP No. 76964 and Civil Case No. 5262).
- Forum shopping, laches, and that petitioners are transferees in good faith for value.
- LRA (via OSG) answered arguing prescription under Act No. 496 (Land Registration Act): without declaration that land was alienable and disposable, possession alone cannot ripen into ownership; also contended for defense of title under Torrens system and statutory prescriptive period.
Trial Court Ruling (RTC Branch 2, Kalibo)
- Order dated April 26, 2012 granted petitioners’ motion to dismiss Civil Case No. 8751.
- Held OCT RO-2222(19502) had become incontestable; validity previously upheld in Civil Case No. 5262 and CA-G.R. SP No. 76964.
- Concluded identity of subject matter and interests existed such that res judicata applied; absolute identity of parties not required—identity of interests sufficed.
- Reconsideration denied on August 9, 2012.
Proceedings and Rulings Before the Court of Appeals
- Appeal filed via CA-G.R. CV No. 05034 by respondents; challenged trial court’s grant of motion to dismiss and alleged grave abuse of discretion by trial court for dismissal sans formal hearing.
- Preliminary procedural issue: respondents’ appellant’s brief initially lacked subject index and page references per Section 13, Rule 44 of the Rules of Court.
- CA initially dismissed appeal by Resolution (Jan 29, 2015) for non-compliance.
- Later, CA granted reconsideration (April 22, 2016) after respondents cured defects; CA emphasized technical dismissals disfavored when substantial compliance exists.
- Appellee’s brief by petitioners defended validity of titles, characterized suit as harassment, and reiterated res judicata and privity arguments.
- Court of Appeals Decision dated April 24, 2017 (assailed):
- Reversed RTC order; VACATED dismissal; REINSTATED Civil Case No. 8751; REMANDED for further proceedings.
- Held CA-G.R. SP No. 76964 is not res judicata to Civil Case No. 8751:
- Found absence of twin elements: identity of parties and identity of causes of action.
- Noted CA-G.R. SP No. 76964 was an original petition for annulment of judgment (not an appeal from Civil Case No. 5262), and any judicial discussion on validity of OCT RO-2222(19502) was merely obiter dictum.
- Court of Appeals denied petitioners’ motion for reconsideration on February 19, 2019.
Other Related Cases Identified in the Record
- Civil Case No. 201-M (5th MCTC Buruanga-Malay) → appealed to RTC Branch 6 as Civil Case No. 7990 → further appealed to Court of Appeals as CA-G.R. SP No. 02859.
- These were ejectment/forcible entry/detainer proceedings; petitioners secured favorable rulings up to the Court of Appeals level and obtained writ of execution and demolition.
- Civil Case No. 5262 (RTC Branch 5, Kalibo; Decision dated May 7, 1999) — complaint for quieting of title filed by heirs of Ciriaco; trial court granted complaint; defendants did not timely seek remedies from trial court; decision lapsed into finality.
- CA-G.R. SP No. 76964 — petition for annulment of judgment filed in Court of Appeals by Marianos and Tapuses, challenging jurisdiction of trial court in Civil Case No. 5262; CA Decision dated June 17, 2004 dismissed petition; Court of Appeals discussion on OCT RO-2222(19502) considered obiter dictum for purposes of collateral attack rules.
- Civil Case No. 6585 (RTC Branch 4, Kalibo) — Estate of Antonio Tapuz and heirs v. Estate of Ciriaco Tirol, Sr. (represented by Cesar T. Tirol) — complaint for annulment of TCTs and recognition of ownership by possession filed June 10, 2002; dismissed by trial court for lack of jurisdiction over indispensable parties, prescription, and laches (Order dated March 29, 2010).
- CA-G.R. CV No. 03634 — Court of Appeals Decision dated July 20, 2016 affirmed dismissal: trial court lacked jurisdiction over indispensable parties, heirs of Ciriaco not properly served, and Section 38 of Act No. 496 provides one-year period to assail registration decree; OCT RO-2222(19502) issued as early as 1932 and thus indefeasible one year thereafter.
- Reconsideration denied (Feb 8, 2017).
- G.R. No. 230135 — this Court affirmed CA-G.R. CV No. 03634 by minute Resolution dated July 12, 2017; decree of affirmance lapsed into finality on December 11, 2017.