G.R. No. 147340. December 13, 2007.
CYNTHIA CRUZ KHEMANI and SHANKER N. KHEMANI, petitioners, vs. THE HEIRS OF ANASTACIO TRINIDAD, represented by NAPOLEON and ROLANDO TRINIDAD, respondents.

FACTS

Petitioner Cynthia Cruz Khemani is the registered owner of Lot No. 107, having purchased it from the heirs of Jose Peña. Respondents, the Heirs of Anastacio Trinidad, claim ownership over a 340-square-meter portion of this lot, alleging open, continuous, and adverse possession since 1950. The lot originated from a public land award. In a prior Supreme Court case, Assistant Executive Secretary for Legal Affairs v. Court of Appeals, the Court affirmed the Peña heirs’ ownership over the entire land, rejecting a claim by another applicant, Basilio Mendoza. The Peña heirs were subsequently issued an Original Certificate of Title.
Respondents filed a complaint for review of decree and/or reconveyance against the Peña heirs and government agencies. They anchored their claim on their long-term possession and a 1976 Miscellaneous Sales Application by Anastacio Trinidad, which was allegedly approved by the Bureau of Lands. The Peña heirs, and later petitioner Khemani as the new owner, moved to dismiss the complaint, arguing it was barred by the prior judgment in the Assistant Executive Secretary case. The trial court initially granted the motion to dismiss but later reconsidered and reinstated the complaint, a decision affirmed by the Court of Appeals.

ISSUE

Whether the complaint for reconveyance filed by respondents is barred by res judicata due to the final judgment in the Assistant Executive Secretary case.

RULING

No, the complaint is not barred by res judicata. The Supreme Court affirmed the Court of Appeals’ decision, ordering a full trial on the merits. The doctrine of res judicata requires, among other elements, identity of parties and identity of causes of action between the prior and subsequent cases. In the Assistant Executive Secretary case, the litigants were Basilio Mendoza and the Peña heirs, with the government as a necessary party. The respondents in the present case, the Heirs of Anastacio Trinidad, were not parties to that prior litigation. There is no identity of parties.
Furthermore, the causes of action are different. The prior case involved a challenge to the administrative award of the land by the Office of the President, essentially a question of which applicant had a better right to a grant of public land. The present case, however, is an action for reconveyance based on a claim of acquisitive prescription. It presupposes that the land, now registered and allegedly private, may have been acquired by respondents through long and adverse possession under the Civil Code. A Torrens title does not shield the holder from a claim for reconveyance based on an implied or constructive trust arising from fraud or prior ownership. Since respondents were not parties to the earlier case and are asserting a distinct legal theory rooted in prescription, they are entitled to their day in court to prove their claim. The trial court must proceed with the trial.