GR L 55152; (August, 1986) (Digest)
G.R. No. L-55152 August 19, 1986
FLORDELIZA L. VALISNO and HONORIO D. VALISNO, petitioners, vs. HON. JUDGE ANDRES B. PLAN, Presiding Judge of the Court of First Instance of Isabela, Second Branch, and VICENCIO CAYABA, respondents.
FACTS
Petitioners Flordeliza and Honorio Valisno purchased two parcels of land in Isabela in 1964. They declared the properties for taxation and exercised exclusive possession. In 1968, private respondent Vicencio Cayaba, claiming ownership via a 1967 deed of sale from different heirs, ousted the petitioners’ caretaker and constructed an apartment on the land. The petitioners subsequently filed a complaint for recovery of possession (Civil Case No. Branch II-895) against Cayaba. The trial court ruled in favor of the Valisnos, but the Court of Appeals reversed this decision in CA-G.R. No. 60142-R, promulgated on January 19, 1978. The appellate court dismissed the complaint, finding that the petitioners failed to sufficiently identify the land in question as the same property they claimed to own, and it recognized Cayaba as the actual possessor with a just title. The Supreme Court denied the petitioners’ petition for review, making the appellate court’s decision final.
ISSUE
Whether the respondent judge correctly dismissed the petitioners’ opposition to Cayaba’s subsequent application for land registration on the ground of res judicata.
RULING
Yes. The Supreme Court affirmed the dismissal, holding that the principle of res judicata squarely applies. The Court of Appeals’ final decision in CA-G.R. No. 60142-R constituted a judgment on the merits regarding the ownership and identity of the disputed land, declaring that the petitioners failed to prove their claim against Cayaba. This prior judgment bars the relitigation of the same issue in the subsequent land registration case. The Court explicitly abandoned its prior ruling in Abellera v. Court of Appeals, which had suggested that a land registration court must still receive evidence despite a plea of res judicata. The new doctrine established is that once res judicata is indubitably shown, the registration court should dismiss either the application or the opposition, as practicality and convenience demand. The Court emphasized that the petitioners had their full day in court during the earlier recovery case, and the final judgment therein remains the law of the case between the parties. Therefore, the respondent judge committed no error in dismissing the opposition based on res judicata.