GR 171756; (March, 2007) (Digest)
G.R. No. 171756 March 27, 2007
Spouses Ricardo Imbat and Lilia Imbat, Petitioners, vs. Spouses Medardo Soliven and Florentina Narvasa and Vinez Hortaleza, Respondents.
FACTS
Respondents Spouses Soliven filed a forcible entry case (Civil Case No. 700) against petitioner Ricardo Imbat and his brother before the MCTC of San Fabian-San Jacinto, Pangasinan. The MCTC ruled in favor of respondents, ordering the Imbat brothers to vacate two parcels of riceland located in Barangay Anonang. This decision was affirmed by the RTC and became final. A writ of execution was enforced, but the Imbat brothers re-occupied the land, leading to a contempt citation and eventual vacation. Subsequently, petitioners filed a complaint for quieting of title (Civil Case No. 98-02478-D) before the RTC of Dagupan, claiming absolute ownership via a 1995 Deed of Donation from Ricardo’s father over a 10,439 sq.m. parcel in Barangay Anonang. They alleged respondents were disturbing their possession by attempting to enforce the ejectment writ over a different property located in Barangay Binday.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s dismissal of the complaint for quieting of title and in declaring respondents as the rightful owners of the disputed property.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ rulings. The core legal logic rests on the conclusive finality of the prior ejectment judgment and the identity of the properties involved. The MCTC decision in the forcible entry case specifically identified the subject land as located in Barangay Anonang. This judgment, having become final and executory, constitutes res judicata on the issue of possession and the identity of the property. Petitioners’ attempt to relitigate ownership through a quieting of title action, alleging a different location (Anonang vs. Binday), constitutes a collateral attack on the final ejectment order, which is impermissible.
Substantively, the evidence preponderated in favor of respondents’ ownership. Respondents’ title was anchored on a 1975 Absolute Sale of Unregistered Land, tax declarations, and an NIA certification, all consistently referring to a property in Barangay Anonang. The Court found credible the explanation that a minor clerical error in one document (mentioning Binday) was due to the vendors being residents of Binday, a neighboring barangay of Anonang. In contrast, petitioners’ evidence, primarily a 1949 receipt (“Recibo”), was insufficient to establish the property’s particulars with certainty. Their proffered Deed of Absolute Sale was not properly authenticated, and a supporting Joint Affidavit was hearsay as the affiants were not presented. Therefore, petitioners failed to substantiate their claim of ownership over a distinct parcel, and the property subject of the quieting of title case is the same land adjudged in the prior ejectment case.