GR 137908; (November, 2000) (Digest)
G.R. No. 137908; November 22, 2000
RAMON D. OCHO, petitioner, vs. BERNARDINO, ERNESTO, PERFECTA, TEOSITA, MANUEL, EPIFANIO, JR. and DELFIN, all surnamed CALOS, respondents.
FACTS
The respondents, heirs of spouses Epifanio and Valentina Calos, filed a complaint before the DARAB seeking the annulment of Emancipation Patents and Transfer Certificates of Title issued to various individuals, including petitioner Ramon Ocho. The land in question, originally covered by a Homestead Patent, was placed under Operation Land Transfer pursuant to P.D. No. 27 and distributed. The Caloses alleged the original farmer-beneficiaries unlawfully conveyed their rights to third parties like Ocho, and argued the land, as a homestead, was exempt from agrarian reform.
The Provincial Adjudicator ruled in favor of the Caloses, ordering the cancellation of all titles issued. On appeal, the Court of Appeals affirmed the decision, specifically directing Ocho and another to restore their lands to the government. The CA found them disqualified as farmer-beneficiaries under R.A. No. 6657, as they allegedly owned other agricultural lands, a finding Ocho contested.
ISSUE
Whether the Court of Appeals erred in ruling that petitioner Ramon Ocho is disqualified as a farmer-beneficiary for owning other agricultural lands.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed the CA’s decision insofar as it directed Ocho to restore his land. The pivotal legal principle applied is the “conclusiveness of judgment” aspect of res judicata. Prior to the DARAB case, the same issue of Ocho’s qualification—specifically, whether he owned other agricultural lands—had been conclusively settled in a separate DAR administrative case (Adm. Case No. 006-90).
In that prior case, the DAR Hearing Officer explicitly found that Ocho was not the owner of other agricultural lands and was therefore qualified. This decision became final and executory after the Caloses’ motion for reconsideration was denied and they failed to appeal. Under the doctrine of conclusiveness of judgment, a fact or question distinctly put in issue and directly determined by a court of competent jurisdiction cannot be disputed or relitigated in a subsequent suit between the same parties. The CA was barred from re-examining this already adjudicated issue. Consequently, Ocho’s title (TCT No. ET-5223) was declared valid.