GR 116680; (August, 1996) (Digest)
G.R. No. 116680 August 28, 1996
Nicolas Veloso, Jr., et al., petitioners, vs. Court of Appeals, Regional Trial Court, Br. 14, Baybay, Leyte, Corsini Miraflor Avellana, et al., respondents.
FACTS
Respondents, heirs of Crispina Peñalosa Miraflor, filed a complaint for quieting of title against petitioners over Lot No. 8422-F, covered by TCT No. 22393 in Crispina’s name. The Regional Trial Court (RTC) ruled in favor of respondents, declaring them absolute co-owners and ordering petitioners to deliver possession. The Court of Appeals affirmed this decision, and the Supreme Court subsequently denied petitioners’ appeal, leading to a final and executory judgment.
Petitioners later sought annulment of the RTC decision before the Court of Appeals, arguing it violated res judicata and the law of the case. They relied on two prior final decisions (Civil Case No. R-205, 1951, and Civil Case No. B-122, 1969, affirmed in 1974) which they claimed upheld their ownership and possession of a portion of Lot No. 8422, including Crispina’s share allegedly sold to their parents in 1948. They contended the RTC in Civil Case No. B-1043 had no jurisdiction to countermand these prior judgments from co-equal courts.
ISSUE
Whether the Court of Appeals erred in refusing to annul the RTC decision in Civil Case No. B-1043 on grounds of res judicata and law of the case.
RULING
The Supreme Court denied the petition, affirming the Court of Appeals. The doctrines of res judicata and law of the case do not apply to bar Civil Case No. B-1043. The legal logic is clear: for res judicata to apply, there must be identity of parties, subject matter, and causes of action between the prior and subsequent cases. Here, the subject matter and causes of action were distinct.
In Civil Case No. R-205, the issue was whether Lot No. 8422 formed part of the estate of Filomena Bermoy; the court ruled it did not. In Civil Case No. B-122, the action was for reconveyance and partition against different defendants (Proculo Peñalosa and Lourdes Bibas), concerning different portions of the lot. Crucially, neither prior case definitively adjudicated the specific validity of Crispina’s 1948 deed of sale or the ownership of the specific sub-lot (8422-F) in question. The RTC in B-1043 examined this deed and found it did not specifically alienate her share in Lot 8422 but referred to shares in estates, thus resolving a matter not previously settled.
Therefore, the final and executory judgment in Civil Case No. B-1043 itself now constitutes res judicata, barring any further relitigation of the ownership of Lot No. 8422-F between these parties. The Court of Appeals correctly dismissed the petition for annulment.