G.R. No. 233909 , November 11, 2024
ERNESTO M. TELLEZ AND JOVINO M. TELLEZ, REPRESENTED BY MELANIA T. MAGPALE, PETITIONERS, VS. SPOUSES JOSE JOSON AND JOVITA JOSON, RESPONDENTS.

FACTS

The petitioners, Ernesto M. Tellez and Jovino M. Tellez, are successors-in-interest of Demetrio Tellez, who was identified as a qualified tenant-beneficiary under the Operation Land Transfer Program (PD 27) over portions of an agricultural land in Nueva Ecija originally owned by Vivencio Lorenzo. Consequently, Ernesto and Jovino were issued emancipation patents for their respective tenanted portions on July 15, 1988. Two prior court cases involved the property. In Civil Case No. C-38, the RTC upheld an Amicable Settlement allegedly executed by Jovino on September 17, 1992, wherein he surrendered his tenancy rights to Vivencio for monetary consideration. In Civil Case No. C-83, the RTC ordered Ernesto and others to vacate the property in favor of Vivencio, citing Jovino’s surrender in the Amicable Settlement. The CA affirmed the denial of a motion to re-open Civil Case No. C-83, and the decision became final and executory on February 15, 2007. Subsequently, Ernesto and Jovino filed a complaint for recovery of possession against the respondents, Spouses Jose and Jovita Joson (heirs of Vivencio), before the Provincial Agrarian Reform Adjudicator (PARAD). The PARAD dismissed the complaint, ruling it was barred by res judicata due to the final RTC decisions and that Jovino had abandoned his rights. The Department of Agrarian Reform Adjudication Board (DARAB) reversed the PARAD, declaring the petitioners as rightful owners by virtue of their emancipation patents and holding that Jovino’s Amicable Settlement was void for violating agrarian laws prohibiting transfer within 10 years. The DARAB ordered the respondents to vacate and surrender Ernesto’s portion, and for Jovino’s portion to be transferred to the Land Bank for distribution to other qualified beneficiaries, as Jovino disqualified himself. The Court of Appeals (CA) reversed the DARAB, ruling that the complaint was barred by res judicata because the RTC decisions had already attained finality, decreeing that Vivencio (and thus his heirs, the respondents) had a better right of possession.

ISSUE

Whether the petitioners’ complaint for recovery of possession is barred by res judicata in view of the finality of the prior Regional Trial Court decisions.

RULING

No, the petition is meritorious. The complaint is not barred by res judicata. For res judicata to apply, there must be, among other elements, identity of subject matter and causes of action between the prior and subsequent cases. The Court held that the subject matter and causes of action in the prior RTC cases and the present agrarian case are not identical. The prior RTC cases were ordinary civil actions for recovery of possession based on the alleged Amicable Settlement and waiver of rights. In contrast, the present case before the DARAB is an agrarian action for recovery of possession founded on the petitioners’ rights as emancipation patent holders under the agrarian reform program. The emancipation patents created vested rights of ownership in favor of the petitioners, making the subject property no longer part of the landowner’s estate. The Court further ruled that the Amicable Settlement, being a transfer of rights over a landholding awarded under agrarian reform within the prohibited 10-year period, is void ab initio for being contrary to law (Section 27 of Republic Act No. 6657 and DAR Administrative Order No. 08-95). A void judgment or contract creates no rights and produces no legal effect; it can be assailed at any time. Since the basis of the prior RTC judgments was a void agreement, the principle of res judicata cannot apply to bar the petitioners from asserting their rights as agrarian reform beneficiaries. The Court reinstated the DARAB decision with modification, ordering the respondents to vacate and surrender possession of both Ernesto’s and Jovino’s tenanted portions to the petitioners.