GR 178495; (July, 2010) (Digest)
G.R. No. 178495; July 26, 2010
SPOUSES RODOLFO A. NOCEDA and ERNA T. NOCEDA, Petitioners, vs. AURORA ARBIZO-DIRECTO, Respondent.
FACTS
Respondent Aurora Arbizo-Directo filed a complaint for Recovery of Possession and Ownership against her nephew, petitioner Rodolfo Noceda, concerning a portion of Lot No. 1121. The Regional Trial Court (RTC) ruled in her favor in 1991, declaring the donation revoked and ordering Noceda to vacate. This decision was affirmed with modification by the Court of Appeals in 1995 and became final after the Supreme Court denied Noceda’s petition in 1999. A writ of execution was issued in 2001.
Subsequently, petitioners purchased a portion of land from spouses Dahipon, who held a title (OCT No. P-9036) derived from a free patent over what was designated as Lot 1121-A. In 2003, despite the final judgment against them, petitioners filed a new action for Quieting of Title against respondent. They sought to enjoin the execution of the prior judgment, claiming ownership based on their new title (TCT No. T-37468) and asserting that the property subject of the first case was part of the land now titled under the Dahipons.
ISSUE
Whether the action for quieting of title is barred by the principle of res judicata.
RULING
Yes, the action is barred by res judicata. The Supreme Court affirmed the dismissal of the complaint. The requisites of res judicata are present: (1) a final judgment on the merits in Civil Case No. RTC-354-I; (2) rendered by a court of competent jurisdiction; (3) identity of parties; and (4) identity of subject matter and causes of action. The core issue of ownership and possession of the disputed portion of Lot 1121 was conclusively settled in the first case, which ordered petitioners to vacate. The cause of action in the second suit, though framed as quieting of title, essentially sought to relitigate the same issue of ownership already adjudicated.
The Court ruled that petitioners cannot circumvent the final judgment by procuring a new title from a different source. The prior judgment is conclusive not only on matters directly adjudged but also on any other matter that could have been raised in relation thereto. Petitioners’ claim of being purchasers in good faith was irrelevant and could have been raised in the prior proceedings. Their status as holders in bad faith, having occupied the land in defiance of the final judgment, and the preclusive effect of res judicata justified the dismissal of their suit for quieting of title.