G.R. Nos. 204052-53, March 11, 2020
HEIRS OF AURIO T. CASIÑO, SR., NAMELY, PATRICIA T. CASIÑO, ESTHER C. MOSQUEDA, EVANGELINE C. RIVERA, GLORY C. MAG-ABO, AURIO T. CASIÑO, JR., MARITES C. RAMOS, ALLAN T. CASIÑO, GENESON T. CASIÑO, AND ALBERT T. CASIÑO, PETITIONERS, VS. DEVELOPMENT BANK OF THE PHILIPPINES, MALAYBALAY BRANCH, BUKIDNON AND GREEN RIVER GOLD, INC., REPRESENTED BY URIEL G. BORJA, RESPONDENTS.

FACTS

On December 28, 1975, spouses Baldomero and Leonarda Casiño obtained a loan from the Development Bank of the Philippines (DBP) secured by a real estate mortgage over three parcels of land in Bukidnon. After the spouses failed to pay, DBP extrajudicially foreclosed the mortgage on March 24, 1977, emerged as the highest bidder, and eventually consolidated ownership after the redemption period lapsed. Baldomero filed a complaint (Civil Case No. 1465) before the Regional Trial Court (RTC) Branch 8 for annulment of the mortgage and foreclosure, quieting of title, redemption, and damages. The RTC Branch 8 dismissed the complaint on August 3, 1990, a decision affirmed by the Court of Appeals (CA) on May 30, 1995, and the Supreme Court’s denial of the petition became final on September 4, 1996. Meanwhile, on April 25, 1994, Baldomero executed a Kasabotan relinquishing his rights over the properties, including a 120-hectare land in Kibulay, to his son Aurio T. Casiño. DBP sold the Kibulay property to Green River Gold, Inc. on January 13, 1997. DBP and Green River obtained a writ of possession from RTC Branch 8, but enforcement was hindered. On March 21, 1997, Aurio filed a complaint for quieting of title (Civil Case No. 2685-97) before RTC Branch 10, claiming ownership of the Kibulay property. DBP and Green River argued the complaint was barred by res judicata due to the final judgment in Civil Case No. 1465 and was defective for not impleading Green River. RTC Branch 10 ruled in favor of Aurio on July 4, 2006, declaring the property different and the prior decision not binding on Aurio, and ordered Green River to vacate. The CA reversed this decision on February 16, 2012, ruling the complaint was barred by res judicata and that the RTC Branch 10 committed grave abuse of discretion in granting execution pending appeal.

ISSUE

Whether the filing of Civil Case No. 2685-97 for quieting of title by Aurio Casiño is barred by the doctrine of res judicata due to the final judgment in Civil Case No. 1465.

RULING

Yes, the petition is not meritorious. The Supreme Court affirmed the CA decision, holding that Civil Case No. 2685-97 is barred by res judicata. The elements of res judicata are present: (1) the prior judgment in Civil Case No. 1465 is final; (2) it was rendered by a court of competent jurisdiction (RTC Branch 8); (3) it is a judgment on the merits (dismissal after due proceedings); and (4) there is identity of parties, subject matter, and causes of action between the two cases. The parties are substantially identical as Aurio derived his claim from his father Baldomero, the original plaintiff. The subject matter is the same Kibulay property, as evidenced by the descriptions in the pleadings and the Kasabotan. The cause of action is identical—ownership and title over the property—as both cases sought to nullify DBP’s foreclosure-based ownership and quiet title in favor of the Casiños. The Court also upheld the CA’s finding that the RTC Branch 10 committed grave abuse of discretion in granting execution pending appeal, as the requisites of good reason and a superior circumstance demanding urgency were not met, and the judgment being executed was from a co-equal court whose final decision could not be disturbed.