GR 148277; (June, 2004) (Digest)
G.R. No. 148277; June 29, 2004
NICANOR MARTILLANO, petitioner, vs. THE HONORABLE COURT OF APPEALS and WILSON PO CHAM, respondents.
FACTS
Abelardo Valenzuela, Jr. filed a complaint before the DARAB to cancel the Certificate of Land Transfer (CLT) and Emancipation Patents (EPs) issued to Nicanor Martillano, claiming he was the landowner and had never instituted Martillano as a tenant. Martillano countered that he was a tenant since 1972, deriving his status from his mother, and that the landowner was the Roman Catholic Church. The Regional Adjudicator ruled for Valenzuela, declaring Martillano not a bona fide tenant and voiding the CLT and EPs. On appeal, the DARAB reversed this, declaring Martillano a bona fide tenant and upholding the validity of his CLT and EPs. Valenzuela did not appeal this DARAB decision, making it final.
Subsequently, Valenzuela sold a 1.3785-hectare portion of the land to Wilson Po Cham. Po Cham later filed a separate petition before the DARAB for the cancellation of Martillano’s EPs, seeking to retain the land under Section 6 of RA 6657. The Provincial Adjudicator ruled in favor of Po Cham. Martillano appealed to the DARAB, which reversed the Provincial Adjudicator and upheld Martillano’s tenancy rights. Po Cham then elevated the case to the Court of Appeals, which reinstated the Provincial Adjudicator’s decision favoring Po Cham. Martillano filed this petition for certiorari.
ISSUE
Whether the Court of Appeals erred in disregarding the final and executory judgment of the DARAB in the first case (DARAB Case No. 062-Bul ’89) which had conclusively established Nicanor Martillano as a bona fide tenant of the landholding.
RULING
Yes, the Court of Appeals committed reversible error. The Supreme Court granted the petition and reinstated the DARAB decision upholding Martillano’s rights. The core legal principle applied is res judicata, specifically “conclusiveness of judgment.” The DARAB’s decision in the first case, which became final after Valenzuela’s failure to appeal, conclusively settled the issue of Martillano’s status as a bona fide tenant and the validity of his CLT and EPs. This finding constitutes the “law of the case” between the parties and their successors-in-interest.
Po Cham, as Valenzuela’s successor-in-interest, is bound by this prior final judgment. He cannot re-litigate the already adjudicated issue of tenancy and land ownership through a subsequent petition. The Court emphasized that public policy demands an end to litigation, and a matter once judicially decided with finality should not be disturbed. Therefore, the Court of Appeals’ decision, which effectively reopened and reversed a settled factual and legal issue, was set aside. Martillano’s CLT and EPs were maintained as valid.