G.R. No. L-27210. June 29, 1972.
Agapito Supio, et al., plaintiffs-appellants, vs. Bernardino Garde, et al., defendants-appellees.

FACTS

The plaintiffs-appellants filed a complaint for partition of a parcel of land, claiming co-ownership based on a reconstituted Transfer Certificate of Title (TCT No. T-41323) issued in the names of both plaintiffs and defendants. The defendants-appellees opposed, asserting exclusive ownership under an earlier, subsisting Original Certificate of Title (OCT No. 15502) issued solely in their names pursuant to a final 1922 Supreme Court decision in R.G. No. 17653 (Government vs. Gicano, et al.). The trial court dismissed the partition complaint, upholding the defendants’ title.

ISSUE

Whether the trial court correctly dismissed the complaint for partition.

RULING

Yes, the dismissal is affirmed. The core legal logic rests on the principle of res judicata and the supremacy of a prior final judgment. The 1922 Supreme Court decision conclusively adjudicated ownership of the lot in favor of the defendants’ predecessors. This decision, having long become final, bars any re-litigation of the issue of title. Consequently, the OCT issued pursuant to that final judgment remains valid and subsisting.
The reconstituted TCT, issued later and purporting to include the plaintiffs, is necessarily null and void as it conflicts with the prior final adjudication and the valid OCT. Since the plaintiffs’ claim of co-ownership derives solely from this void title, they have no valid cause of action for partition. The main opinion and concurrences clarify that the land registration court, where a related petition for relief is pending, must now cancel the reconstituted TCT, as this Court’s affirmance has already resolved the issue of which title prevails.