G.R. No. 233767 , August 27, 2020.
HEIRS OF EUTIQUIO ELLIOT, REPRESENTED BY MERIQUITA ELLIOT, JOHUL ELLIOT, RENE ELLIOT, AND PERFECTO ELLIOT, PETITIONERS, VS. DANILO CORCUERA, RESPONDENT.

FACTS

Respondent Danilo Corcuera, represented by his attorney-in-fact, filed a Complaint for Recovery of Possession and Damages against petitioners Heirs of Eutiquio Elliot. He alleged he was the registered owner of a parcel of land in Calapacuan, Subic, Zambales, covered by Original Certificate of Title (OCT) No. P-7061, and that petitioners entered the land without his consent in 1994, planted trees, and refused to vacate despite demands. Petitioners countered that they had filed an administrative protest with the Department of Environment and Natural Resources (DENR) to annul respondent’s title, which created a prejudicial question. They also claimed superior right of possession, having occupied the land since 1965, and that respondent’s title was obtained through fraud, as indicated by a DENR Certificate of Finality. The Regional Trial Court (RTC) dismissed the complaint, finding petitioners had acquired ownership through acquisitive prescription and that respondent’s title was irregularly obtained. The Court of Appeals (CA) reversed the RTC, ruling that respondent’s title gave him a better right of possession and that the validity of the title could not be collaterally attacked. Meanwhile, in a parallel case (G.R. No. 231304), petitioners filed an action for nullification of respondent’s free patent and OCT. The RTC ruled in favor of petitioners, ordering reconveyance, and this decision was affirmed by the CA and ultimately became final after this Court denied respondent’s petition.

ISSUE

Whether the Court of Appeals erred in reversing the RTC and declaring respondent Danilo Corcuera to have a better right of possession over the land covered by OCT No. P-7061.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the assailed CA Decision and Resolution, and REINSTATED the RTC Decision dismissing the complaint for recovery of possession. The Court applied the principle of res judicata by conclusiveness of judgment, noting that the factual issue of petitioners’ possession had been conclusively settled in the final and executory judgment in G.R. No. 231304. In that case, it was definitively ruled that petitioners had been in open, continuous, exclusive, and notorious possession of a 14,093-square-meter portion of the lot for over thirty years, and that respondent obtained his title through fraud by including their occupied property in his free patent application. Consequently, respondent failed to prove his claim of de facto possession over the disputed portion, and his action for recovery of possession must fail.