GR 133547; (November, 2003) (Digest)
G.R. No. 133547 & G.R. No. 133843; November 11, 2003
Heirs of Antonio Pael and Andrea Alcantara and Crisanto Pael, and Maria Destura, Petitioners, vs. Court of Appeals, Jorge H. Chin and Renato B. Mallari, Respondents.
FACTS
The case originated from a complaint filed by Maria Destura seeking the annulment of a Memorandum of Agreement (MOA) and two Transfer Certificates of Title (TCT Nos. 52928 and 52929) over Lot Nos. 588-A and 588-B in Quezon City. Destura alleged that respondents Jorge Chin and Renato Mallari, formerly her husband Pedro’s agents, fraudulently obtained the titles to the properties. The Regional Trial Court (RTC) rendered a judgment by default, nullifying both the MOA and the titles, finding the documents supporting the transfer to Chin and Mallari spurious due to missing notarial records and certifications.
While the case was on appeal, the University of the Philippines (UP) successfully intervened, asserting ownership of the disputed lots as part of its indefeasible Diliman Campus. The Court of Appeals initially ruled in favor of Chin and Mallari, declaring them the absolute owners. This prompted the Supreme Court to remand the case to the CA to receive evidence on the conflicting claims between the private respondents and UP.
ISSUE
The core issue is whether the titles of respondents Chin and Mallari over the subject properties can prevail against the ownership claim of the University of the Philippines.
RULING
The Supreme Court ruled in favor of UP, setting aside the CA decision that recognized Chin and Mallari’s ownership. The Court upheld the indefeasibility of UP’s title over its Diliman Campus, a principle firmly established in a long line of jurisprudence. The legal logic rests on the doctrine of res judicata and the law of the case. Previous final and executory judgments in favor of UP regarding its Diliman property have conclusively settled its ownership. These prior adjudications bar the re-litigation of UP’s title, regardless of the present action’s different parties or grounds.
The Court found the attempt by Chin and Mallari to assert ownership as another “crass attempt to grab” part of the campus. Their claim, based on titles derived from a dubious chain, could not overcome the settled and paramount right of UP. Consequently, the Supreme Court ordered the cancellation of TCT Nos. 52928 and 52929 in the names of Chin and Mallari and dismissed their related quieting of title suit against UP. The ruling reinforces that established final judgments regarding land ownership constitute the law of the case and bind subsequent proceedings.