G.R. No. 200773, July 8, 2015
Republic of the Philippines vs. Angeline L. Dayaoen, Agustina Tauel, and Lawana T. Batcagan

FACTS

Respondents Angeline Dayaoen, Agustina Tauel, and Lawana Batcagan filed an Application for Registration of three parcels of land (Lots 1, 6, and 7) in Barangay Tabangaoen, La Trinidad, Benguet, with a total area of 1,634 square meters. The properties were originally owned and possessed since pre-war time by Antonio Pablo, Angeline’s grandfather-in-law. In 1963, Antonio gave the lands to Angeline and her husband Dado Pablo as a wedding gift. Angeline sold Lots 6 and 7 to co-respondents Agustina and Lawana in 1976 and 1977, respectively. Respondents claimed they and their predecessor-in-interest have been in open, continuous, exclusive, and notorious possession in the concept of an owner since June 12, 1945, and had declared the properties for taxation. The Regional Trial Court (RTC) granted the application in an Amended Decision dated September 11, 2008. The Court of Appeals affirmed this decision on February 23, 2012. Notably, the respondents had previously filed a similar application for the same property in 1979, docketed as LRC Case No. N-453, which was dismissed by the RTC in a Decision dated December 26, 1994, for failure to prove the required possession. That prior decision became final and executory as respondents did not appeal.

ISSUE

Whether the respondents have sufficiently established their registrable title over the subject properties, particularly in light of the prior final and executory judgment in LRC Case No. N-453 which dismissed their earlier application for registration of the same property.

RULING

The Supreme Court granted the petition and reversed the decisions of the lower courts. The Court held that the prior judgment in LRC Case No. N-453, which had become final and executory, constitutes res judicata and bars the subsequent application for registration of the same property. The elements of res judicata were present: the prior judgment was final; it was rendered by a court with jurisdiction; it was a judgment on the merits; and there was identity of parties, subject matter, and cause of action between the prior and present cases. The Court emphasized that the dismissal of the first application for failure to prove possession since June 12, 1945, settled the issue of respondents’ title conclusively. The principle of res judicata promotes stability in judicial decisions and prevents endless litigation. Consequently, respondents are precluded from re-litigating the issue of their ownership and possession, and their present application for registration must be denied.