GR 122202; (May, 2005) (Digest)
G.R. No. 122202 ; May 26, 2005
HEIRS OF THE LATE FAUSTINA ADALID, petitioners, vs. THE COURT OF APPEALS, THE REGISTER OF DEEDS OF BAIS CITY, and SPOUSES HERMAN GREGORIO AND CORNELIA MONTESA GREGORIO, respondents.
FACTS
The petitioners, heirs of Faustina Adalid, filed a complaint for Annulment of Titles and Damages (Civil Case No. 136-B) against the respondents. They claimed continuous, exclusive possession of Lot No. 211 since 1900, asserting that Cadastral Decree No. 260144 and the subsequent Original Certificate of Title No. 5367 issued in 1927 in favor of spouses Gorgonio Montesa and Manuela Teves were fraudulently obtained. The petitioners alleged they only recently discovered this fraud. The respondents, the Gregorio spouses who are successors-in-interest, moved to dismiss the complaint on the ground of res judicata. They argued that the ownership and possession of the same Lot No. 211 had already been conclusively settled in a prior case, Civil Case No. 4049, wherein a decision was rendered against the petitioners’ predecessors-in-interest, which was affirmed by the Court of Appeals.
ISSUE
Whether the principle of res judicata bars the petitioners’ action for annulment of title.
RULING
Yes, the action is barred by res judicata. The Supreme Court affirmed the lower courts’ dismissal of the complaint. For res judicata to apply, four identities must concur: (1) identity of parties; (2) identity of subject matter; (3) identity of causes of action; and (4) identity of reliefs sought. All these elements are present. The parties in the present case are substantially identical to or are successors-in-interest of the parties in Civil Case No. 4049. The subject matter is identically Lot No. 211 of the Bais Cadastre. The Court found that the reference to a different cadastral decree number (260177) in the prior decision was a mere clerical error, as the body of that decision and the pleadings in both cases unequivocally refer to the same physical lot. The cause of action in both suits is fundamentally the same: a claim of ownership by the petitioners/heirs based on alleged prior possession, pitted against the registered title derived from the cadastral decree. The relief sought—recovery of ownership and possession—is also identical. The final judgment in the prior case, having attained finality, constitutes an absolute bar to a subsequent action involving the same claim. The petitioners cannot re-litigate the issue of ownership under the guise of a new action alleging a recent discovery of fraud, as the matter is deemed conclusively settled.