GR 144103; (August, 2005) (Digest)
G.R. No. 144103 . August 31, 2005
AGUEDA DE VERA-CRUZ, ET AL., Petitioners, vs. SABINA MIGUEL, Respondent.
FACTS
Petitioners are the registered owners of a parcel of land in San Mateo, Isabela, covered by TCT No. T-70778. The land originated from a homestead patent granted to Angel Madrid, whose heirs later sold it to petitioners’ predecessor, Teodoro Dela Cruz. The ownership and right to possession of this land had been conclusively settled in prior litigations, including a reversion case and an accion publiciana, where the courts upheld the title of Dela Cruz and ordered various occupants to vacate. Respondent Sabina Miguel occupies a portion of this land. Petitioners filed a complaint for Recovery of Possession with Damages against her in the RTC, which ruled in their favor.
The RTC granted petitioners’ motion for summary judgment, finding no genuine factual issue as respondent’s claim of possession since 1946 and an alleged award from the municipal government were deemed unsubstantiated and barred by prior final judgments. The Court of Appeals reversed, holding that summary judgment was improper because respondent’s answer raised genuine issues of fact regarding her possession and the identity of the land she occupied, necessitating a full trial.
ISSUE
Whether the Court of Appeals erred in reversing the RTC’s grant of summary judgment in favor of the petitioners.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the RTC’s decision. The Court held that summary judgment was correctly rendered as no genuine issue of fact existed for trial. Respondent’s claim of possession since 1946 and a municipal award were conclusively barred by res judicata. The land’s ownership and the petitioners’ right to possess it had been definitively adjudicated in the prior consolidated cases (CA-G.R. Nos. 31252-R and 31309-R), which became final and executory. These prior judgments, which involved the same land and ordered all occupants to vacate in favor of petitioners’ predecessor, bind the respondent as a successor-in-interest to the original defendants or as a privy. Her defenses were mere sham, as they had already been rejected in the prior proceedings. Furthermore, her claim of a different property identity was belied by the technical description in her tax declaration, which matched the petitioners’ titled land. Thus, petitioners, as registered owners, have a clear right to possession, and respondent’s occupation is without legal basis.