Case Summary (G.R. No. 97319)
Summary of Claims and Background
The petitioners assert that their parents settled on the disputed lot in 1959, during a government land distribution in Bago-Bantay. Conversely, the Lladones moved into an adjacent lot in 1961, and later sought title to the disputed lot. Allegations arose that the Lladones obtained a title (TCT No. 286437) to the lot in question in 1982 without knowledge of the Swans' ownership claims. The Swans filed a Civil Case (Q-90-5183) in April 1990 against the Lladones for annulment and cancellation of the title.
Previous Legal Proceedings
The case escalated through various stages beginning with earlier actions by the Gillones against different occupants of the land, including petitioners' mother, Maria Swan. The conflicting cases included attempts filed by the Lladones for possession and ejectment, resulting in a decision favoring them which was not contested by the petitioners at different stages. By February 1992, the RTC allowed the Lladones to execute an eviction pending appeal based on an earlier decision.
Issues of Res Judicata
A significant legal point raised is the doctrine of res judicata. The Supreme Court noted that the petitioners had pursued similar claims in a prior case (filed in 1977), where a final judgment was issued in favor of the Lladones. Even though the petitioners attempted a new action in 1990, the Court held that the issues were substantially the same as in the earlier case, meeting the criteria for res judicata, and hence, the 1990 case was barred from proceeding.
Jurisdictional Matters and Appeal Remedies
The Court addressed the nature of the claims against the National Housing Authority (NHA) and highlighted that the proper legal remedy should involve a special civil action for certiorari, alleging abuse of discretion by the NHA, rather than a direct annulment action as improperly attempted by the petitioners. The decision in Raymundo vs. PHHC was cited to underscore the limitations of judicial review over administrative actions.
###Court’s Final Determination Ultimately, the Supreme Court set aside the decision of the respondent Court of Appeals which had di
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Case Background
- The case involves a dispute between the Swan brothers (petitioners) and the Lladones spouses (respondents) regarding a property designated as Block 5, Lot 21 of the Bago-Bantay, Quezon City Subdivision Plan.
- The petitioners claim their parents, Atanacio B. Swan and Maria T. Swan, occupied the disputed lot since 1959, while the Lladones began occupying a neighboring lot in 1961.
- The petitioners assert that their application to purchase the lot was mishandled, leading to a series of legal actions, including a civil case for annulment and cancellation of title against the Lladones.
Legal Proceedings and Actions
- The Lladones filed an application to purchase the disputed lot in 1977, which the petitioners claim was done without their knowledge.
- The Lladones obtained Transfer Certificate of Title (TCT) No. 286437 on March 26, 1982.
- The petitioners filed Civil Case Q-90-5183 against the Lladones for annulment and cancellation of the title after the Quezon City RTC denied the Lladones' motion to dismiss.
- The Quezon City RTC’s ruling was reversed by the Court of Appeals, which found that the petitioners should have filed a special civil action for certiorari against the National Housing Authority (NHA).
Historical Context of the Property Dispute
- The property had been the subject of sev