G.R. No. 213209 . January 16, 2017.
Republic of the Philippines, Petitioner, vs. Gertrudes V. Susi, Respondent.

FACTS

Respondent Gertrudes V. Susi filed a petition for the reconstitution of Transfer Certificate of Title (TCT) No. 118999, covering a large parcel of land in Quezon City, alleging the original title was destroyed in a 1988 fire at the Registry of Deeds. She anchored her petition on the presentation of the owner’s duplicate copy of the title. The Regional Trial Court (RTC) granted the petition. The Republic, through the Office of the Solicitor General, moved to vacate the judgment, arguing the petition was barred by res judicata due to the prior dismissal of a similar reconstitution case filed by Susi in another branch. The RTC denied the motion, and the Court of Appeals affirmed, holding that res judicata did not apply and that Susi had sufficiently proven her case.

ISSUE

Whether the petition for reconstitution is barred by res judicata.

RULING

No, the petition is not barred. The Supreme Court affirmed the lower courts. For res judicata to apply, there must be a final judgment on the merits. The prior dismissal of Susi’s earlier petition in a different branch was based on her failure to comply with specific technical requirements under Republic Act No. 26 , such as properly alleging the names of occupants and adjoining owners. This constitutes a dismissal based on a technicality, not an adjudication on the merits of her claim of ownership or the validity of the title. Consequently, she was not precluded from refiling a petition that cured these procedural defects. The Court found that in the present case, Susi satisfactorily complied with jurisdictional requirements, including publication and posting, and presented the owner’s duplicate certificate and a certification of the fire from the Registry of Deeds. Therefore, the RTC correctly acquired jurisdiction and properly granted the reconstitution based on the evidence presented. The defense of res judicata was correctly rejected.