G.R. No. 191101 , October 1, 2014
SPOUSES MARIO OCAMPO and CARMELITA F. OCAMPO, Petitioners, vs. HEIRS OF BERNARDINO U. DIONISIO, represented by ARTEMIO SJ. DIONISIO, Respondents.

FACTS

On August 28, 1996, Bernardino U. Dionisio filed a complaint for forcible entry (Civil Case No. 96-0031) with the Municipal Trial Court (MTC) of Cardona, Rizal, against Mario Ocampo and Felix Ocampo, seeking to recover possession of a portion of his property covered by Original Certificate of Title (OCT) No. M-4559, alleging they built a piggery thereon without consent. Mario Ocampo, in his answer, claimed the land was owned by his wife, Carmelita Ocampo, through inheritance, and they had been in possession since 1969. The MTC dismissed the forcible entry complaint on September 12, 1997, ruling Dionisio failed to establish prior possession. Dionisio’s appeal was denied for being filed out of time. Dionisio died on September 27, 1997.
Subsequently, on July 3, 1998, the heirs of Dionisio (respondents) filed a complaint for recovery of possession (Civil Case No. 98-0006) with the MTC against the spouses Mario and Carmelita Ocampo (petitioners), seeking to recover the same property. They asserted Dionisio acquired the property by purchase in 1945, obtained a free patent, and was issued OCT No. M-4559 in his name in 1987, and that Mario built a piggery on a portion in 1995 without consent. The petitioners, in their answer, reiterated Carmelita’s ownership through inheritance and their possession since 1969, and claimed the complaint was barred by res judicata due to the final decision in the forcible entry case.
On February 18, 2008, the MTC dismissed the recovery of possession complaint on the ground of res judicata, stating the issue of possession was conclusively settled in the forcible entry case. On appeal, the Regional Trial Court (RTC) reversed the MTC, declaring the respondents entitled to possession as lawful owners under OCT No. M-4559, ordering the petitioners to vacate, and awarding attorney’s fees and litigation expenses. The RTC ruled res judicata did not apply because the forcible entry case involved only possession, while the recovery case involved both possession and ownership; thus, there was no identity of causes of action. The RTC also found the respondents sufficiently proved ownership via the title, while the petitioners did not.
The petitioners elevated the case to the Court of Appeals (CA), reiterating res judicata, challenging the proof of ownership, and arguing laches. The CA affirmed the RTC, holding no identity of cause of action between forcible entry (possession) and recovery of possession (ownership and possession), confirming the respondents’ ownership via OCT No. M-4559, and ruling laches inapplicable. The CA denied reconsideration.

ISSUE

1. Whether the final decision in the forcible entry case constitutes res judicata, barring the recovery of possession complaint.
2. Whether the respondents established their ownership of the subject property.
3. Whether the respondents’ cause of action is barred by laches.

RULING

The Supreme Court denied the petition and affirmed the CA Decision and Resolution.
1. On res judicata: The Court ruled res judicata in the concept of “bar by prior judgment” does not apply. While the first three requisites (final former judgment, jurisdiction, judgment on merits) are present, there is no identity of causes of action between the forcible entry case and the recovery of possession case. Forcible entry (accion interdictal) solely determines physical or material possession (possession de facto) and does not adjudicate ownership. Recovery of possession (accion publiciana) involves the right to possess as an attribute of ownership, requiring a determination of a better right of possession. The causes of action are distinct; thus, the forcible entry judgment does not bar the recovery suit.
2. On ownership: The Court held the respondents, as successors-in-interest of Dionisio, sufficiently established ownership through OCT No. M-4559 registered in Dionisio’s name. The Torrens title serves as conclusive evidence of ownership. The petitioners’ claim of ownership by inheritance was unsupported by sufficient evidence. As registered owners, the respondents have the right to possess the property.
3. On laches: The Court ruled laches does not apply. The respondents’ right to recover possession, stemming from their ownership of registered land under the Torrens system, is imprescriptible. Prescription and laches cannot run against the registered owner’s title to registered land. The registered owner may demand return of the property at any time if the possession was unauthorized or merely tolerated.