Title
Superiora Locale Dell' Istituto Delle Suore Di San Giuseppe Del Caburlotto, Inc. vs. Republic
Case
G.R. No. 242781
Decision Date
Jun 21, 2022
Petitioner sought land registration for two lots; CA dismissed due to res judicata and jurisdiction issues. SC reversed, ruling res judicata inapplicable, retroactively applied RA 11573, and upheld joinder of causes, remanding for compliance with new law.
res judicata
registration proceedings
application for registration

Case Summary (G.R. No. 242781)

Factual Background

Petitioner sought judicial confirmation and issuance of an original certificate of title over two parcels identified as Lots No. 1341-A (2,876 square meters) and No. 1341-B (136 square meters) in Amadeo Cadastre by an Application for Registration filed on March 22, 2013. Petitioner asserted acquisition by deed of extrajudicial settlement with absolute sale and alleged open, continuous, exclusive and notorious possession under a bona fide claim of ownership since June 12, 1945 or earlier. Tax Declarations and assessed values were pleaded: Lot No. 1341-A at P299,100.00 and Lot No. 1341-B at P14,140.00.

Trial Court Proceedings

The Office of the Solicitor General opposed the application. The RTC, by Order dated April 11, 2016, dismissed the application over Lot No. 1341-A on the ground of res judicata, reasoning that a prior Court of Appeals decision in CA-G.R. CV No. 92767 had become final and disposed of identical issues and parties, and dismissed the application over Lot No. 1341-B for lack of jurisdiction because its assessed value fell below the RTC threshold. The RTC found identity of parties, subject matter and cause of action and concluded the prior CA judgment was on the merits and final.

Court of Appeals Ruling

On appeal, the Court of Appeals affirmed the RTC in a Decision dated April 6, 2018. The CA held that all requisites for res judicata under the doctrine of bar by prior judgment were present as to Lot No. 1341-A: finality, adjudication on the merits, jurisdiction of the prior tribunal, and identity of parties, subject matter and cause of action. The CA likewise affirmed the RTC’s dismissal of Lot No. 1341-B for lack of jurisdiction, reasoning that the assessed value of each lot must be considered separately in determining jurisdiction.

Issue Presented

The core issue before the Supreme Court was whether the Court of Appeals correctly affirmed the RTC’s dismissal of petitioner’s registration application over Lot No. 1341-A on the ground of res judicata and over Lot No. 1341-B on the ground of lack of jurisdiction.

Parties' Contentions

Petitioner contended that a judgment dismissing an application for registration does not necessarily have the conclusive effect of res judicata, especially when the dismissal was for insufficiency of evidence and did not determine ownership. The OSG maintained that the first CA decision had become final and barred relitigation as to Lot No. 1341-A and argued that the RTC lacked jurisdiction over Lot No. 1341-B because its assessed value fell below the jurisdictional threshold.

Supreme Court Disposition

The Supreme Court granted the petition, reversed and set aside the CA Decision dated April 6, 2018 and Resolution dated October 23, 2018, and remanded the case to the RTC, Branch 18, Tagaytay City, for further proceedings. The Court held that res judicata did not apply to the registration proceeding over Lot No. 1341-A and that the RTC must apply the amended standards under R.A. No. 11573 to pending registration cases.

Legal Basis: No Application of Res Judicata to Registration Proceedings

The Court reaffirmed controlling precedent that the doctrine of res judicata requires finality, adjudication on the merits, jurisdiction, and identity of parties, subject matter and cause of action, as stated in Filinvest Land, Inc. v. Court of Appeals. The Court nonetheless explained that res judicata does not apply to registration proceedings where the prior dismissal did not constitute a conclusive adjudication between adversarial parties or where the prior case was dismissed without a hearing or for insufficiency of evidence. The Court relied on Vda. de Santos v. Diaz and related authorities to emphasize that the Land Registration Act contemplates recurring opportunities to cure defects in imperfect titles by discovery of new evidence or passage of time, and that a decree dismissing an application does not necessarily bar another application.

Legal Basis: Retroactive Application of R.A. No. 11573 as Curative

The Court found that R.A. No. 11573 is a curative statute enacted to simplify, update and harmonize land laws and to provide land tenure security. Because it is curative and remedial in nature, the Court held that R.A. No. 11573 may be applied retroactively to applications for judicial confirmation of title pending as of its effective date, September 1, 2021. The Court cited prior decisions on curative statutes and followed the guidance in Republic v. Pasig Rizal Co., Inc. that R.A. No. 11573 shortens the adverse possession requirement and relaxes the proof of land classification.

Effect of R.A. No. 11573 on Substance of Proof

Under the amended Section 14 of P.D. No. 1529, as amended by R.A. No. 11573, an applicant need only show open, continuous, exclusive and notorious possession under a bona fide claim of ownership for at least twenty years immediately preceding filing, and the subject land must not exceed twelve hectares. The Court observed that evidence formerly insufficient to meet the more stringent requirement of possession "since June 12, 1945" may now suffice under the twenty-year standard. The Court further noted that Section 7 of R.A. No. 11573 prescribes that a duly signed certification by a duly designated DENR geodetic engineer imprinted on the approved survey plan is sufficient proof that the land is alienable and disposable, eliminating the older, more onerous requirements arising from precedent such as Republic of the Philippines v. T.A.N. Properties, Inc.

Jurisdictional Joinder and Lot No. 1341-B

The Court recognized that Lot No. 1341-B, assessed at P14,140.00, fell within the delegated jurisdiction of MeTCs/MTCs/MCTCs under Section 34 of P.D. No. 1529 as amended. Nevertheless, the Court permitted joinder of causes of action under Section 18 of P.D. No. 1529 and Section 5, Rule 2 of the Rules of Civil Procedure, because petitioner’s application included two parcels w

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