G.R. No. 25660, G.R. No. 32065, G.R. No. 33677 February 23, 1990
LEOPOLDO VENCILAO, ET AL., plaintiffs-appellants/petitioners, vs. TEODORO VANO, ET AL., defendants-appellees/respondents.

FACTS

These consolidated cases involve disputes over parcels of land in Bohol. In Land Registration Case No. 76, the heirs of Juan Reyes successfully obtained Original Certificate of Title No. 400 for the subject properties. Subsequently, numerous individuals, claiming ownership by purchase or inheritance and alleging possession for over thirty years, filed a complaint for reconveyance (Civil Case No. 1533). They asserted that their lands were included in the Reyes registration through mistake or fraud. The trial court initially denied a motion to dismiss but later partially granted it, dismissing the cases of several plaintiffs on the ground of res judicata, as their claims were deemed barred by the final judgment in the land registration case.
In related proceedings, the registered owners sought to enforce their title. The court issued writs of possession and, later, orders for demolition against the structures of the petitioners who refused to vacate. The petitioners were also found guilty of contempt for disobeying court orders. They challenged these subsequent orders through petitions for certiorari, arguing that the pendency of their appeal in the reconveyance case and a related certiorari petition barred the issuance and execution of the demolition order.

ISSUE

The primary issues are: (1) Whether the dismissal of some plaintiffs’ reconveyance claims based on res judicata was correct; and (2) Whether the trial court acted with grave abuse of discretion in issuing orders for contempt and demolition while related petitions were pending.

RULING

The Supreme Court affirmed the trial court’s orders. On the first issue, the Court upheld the application of res judicata. The final decree of registration in the land registration case, which became incontrovertible after one year, barred the reconveyance suit for those plaintiffs whose interests were directly adjudicated or could have been litigated in that prior proceeding. The principle of conclusiveness of judgment prevents re-litigation of claims pertaining to the same property and parties.
On the second issue, the Court ruled that the trial court did not commit grave abuse of discretion. The pendency of a certiorari petition challenging a contempt order (G.R. No. L-32065) did not automatically stay the execution of the final and executory writs of possession. A writ of possession is a ministerial duty following a registration decree. The accompanying writ of demolition is a necessary complement to give full effect to the writ of possession, especially when occupants refuse to remove their structures. The Court cited Meralco vs. Mencias, stating that such a writ is reasonably necessary to deliver complete possession to the registered owner. The trial court’s orders were thus valid exercises of its jurisdiction to enforce its final judgments.