G.R. No. L-15644. February 29, 1964.
MAXIMO L. GALVEZ and ELPIDIO TIBURCIO, plaintiffs-appellants, vs. MARIANO SEVERO TUASON Y DE LA PAZ, ET AL., defendants, UNIVERSITY OF THE PHILIPPINES (UP) and THE PEOPLE HOMESITE AND HOUSING CORPORATION (PHHC), defendant-appellees.

FACTS

Plaintiffs-appellants Maximo L. Galvez and Elpidio Tiburcio, as heirs of Eladio Tiburcio, filed a complaint for annulment of technical descriptions and recovery of over 400 hectares of land in Quezon City, with damages, against the Tuasons, the Register of Deeds, the UP, and the PHHC. They alleged open, continuous, and exclusive possession of the land, claiming it was wrongfully included in Original Certificate of Title No. 735 of the Tuasons through detachable sheets. They further alleged the Tuasons donated the land to themselves, obtained TCT No. 2680, and subsequently sold the property to the UP and PHHC.
The UP and PHHC filed motions to dismiss. During the hearing on these motions, the defendants-appellees presented crucial documentary evidence. The UP presented records showing that Marcelino Tiburcio, representing the same heirs, had previously filed an application for registration of the same land based on a Spanish title, which was dismissed in 1955. They also presented records of a subsequent reconveyance suit (Civil Case No. Q-2663) filed by the same heirs against the PHHC and UP, which was dismissed by the trial court and whose dismissal was affirmed by the Supreme Court in G.R. No. L-13479 on December 14, 1958. The PHHC presented OCT No. 735 issued in 1914 to the Tuasons and the corresponding decree, showing the land was judicially registered in the Tuasons’ favor.

ISSUE

Whether the trial court correctly dismissed the complaint against the UP and PHHC on the grounds of lack of sufficient cause of action, bar by prior judgment, and litis pendentia.

RULING

Yes, the dismissal was proper. The Supreme Court affirmed the trial court’s order. The legal logic rests primarily on the doctrine of res judicata, specifically bar by prior judgment. The record indisputably showed that the ownership of the same property had been conclusively settled in prior final judgments. First, the Tiburcio heirs’ application for land registration was dismissed. Second, their subsequent action for reconveyance against the same appellees (PHHC and UP) was also dismissed, a dismissal affirmed by the Supreme Court. These prior decisions constitute a bar to the instant action, which seeks to relitigate the same issue of ownership over the same property.
Furthermore, the complaint failed to state a cause of action against the appellees UP and PHHC. For a transferee of registered land to be bound by a trust or to have its title annulled, the complaint must allege that the transferee was a purchaser in bad faith or had notice of the alleged flaw in the vendor’s title. The appellants’ complaint contained no such allegation against the UP and PHHC. As innocent purchasers for value of property covered by a Torrens title, their rights are protected. The order of dismissal was therefore correct on both grounds.