G.R. No. 198223 , February 18, 2015
HEIRS OF TIMBANG DAROMIMBANG DIMAAMPAO, represented by CABIB D. ALAWI, Petitioners, vs. ATTY. ABDULLAH ALUG, HADJI BOGABONG BALT and HEIRS OF HADJI ALI PETE PANGARUNGAN, represented by HADJA SITTIE SALIMA PANGARUNGAN, Respondents.

FACTS

Petitioners, heirs of Timbang Daromimbang Dimaampao, filed a complaint in the Regional Trial Court (RTC) of Lanao del Sur for declaration of a deed of sale as nullity, quieting of title, and damages. They claimed ownership over a parcel of land covered by OCT No. RP-355, acquired through inheritance from their grandmother Timbang, who allegedly received it as a dowry from her husband Cota Dimaampao. Petitioners asserted that after Cota and Timbang divorced, Timbang and her daughters remained in possession. They alleged that on April 10, 1978, without their knowledge, Cota executed a deed of sale over the land in favor of respondents, which they claimed was invalid as Cota had no ownership rights. They further stated that a prior case (Civil Case No. 2410) involving the same land, which annulled deeds of sale and donation by Cota to other parties, had attained finality but did not implicate them.
Respondents, in their answer, denied petitioners’ claims and asserted ownership since 1978. They argued that the validity of the deed of sale had already been upheld in Civil Case No. 2410, which had attained finality, and raised special and affirmative defenses including prescription, laches, and the Statute of Frauds.
The RTC issued an order dated March 6, 2006, denying respondents’ special and affirmative defenses as matters of evidence to be resolved at trial. Respondents filed a motion for reconsideration, which was denied by the RTC on February 29, 2008. Respondents then filed a petition for certiorari with the Court of Appeals (CA).
The CA granted the petition, setting aside the RTC orders and dismissing the complaint. The CA found that the RTC disregarded the final decision in Civil Case No. 2410, which declared Cota as the lawful owner and possessor, making res judicata applicable. The CA also ruled that petitioners’ action had prescribed, as it was filed more than 26 years after the deed of sale was annotated in 1978.

ISSUE

1. Whether the CA erred in granting the petition for certiorari and dismissing the complaint based on res judicata and prescription.
2. Whether a motion for extension of time to file a motion for reconsideration is allowed.
3. Whether the special and affirmative defenses raised in the answer are matters of evidence to be resolved after trial.

RULING

The Supreme Court denied the petition and affirmed the CA decision.
1. On the propriety of certiorari: The RTC order dated March 6, 2006, denying respondents’ special and affirmative defenses, was an interlocutory order, as it did not finally dispose of the case but directed the case to proceed to trial. Interlocutory orders are not appealable but may be challenged via a petition for certiorari under Rule 65 if issued with grave abuse of discretion. The CA correctly entertained the petition, as the RTC’s disregard of the final judgment in Civil Case No. 2410 constituted grave abuse of discretion.
2. On res judicata and prescription: The CA correctly applied res judicata. Civil Case No. 2410, which involved the same land and parties (through predecessors-in-interest), had already attained finality and declared Cota as the lawful owner and possessor. This precluded relitigation of ownership. Additionally, petitioners’ action for quieting of title had prescribed. An action for quieting of title must be filed within 10 years from the date the cloud on title is created. The deed of sale was annotated on April 11, 1978, but petitioners filed the complaint only in 2005, well beyond the prescriptive period.
3. On procedural matters: The Supreme Court did not explicitly address the issue of a motion for extension to file a motion for reconsideration, as the focus was on the substantive merits of res judicata and prescription. However, it upheld the CA’s decision, implying that procedural technicalities did not outweigh the substantive grounds for dismissal.
The Supreme Court affirmed the CA’s dismissal of the complaint, ruling that the RTC committed grave abuse of discretion in ignoring a final judgment and that petitioners’ action was barred by res judicata and prescription.