G.R. No. 242781 , June 21, 2022
SUPERIORA LOCALE DELL’ ISTITUTO DELLE SUORE DI SAN GIUSEPPE DEL CABURLOTTO, INC., PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner filed an application for registration over Lot Nos. 1341-A and 1341-B. The Regional Trial Court (RTC) dismissed the application primarily on the ground of res judicata. The Court of Appeals (CA) affirmed the RTC’s dismissal. The ponencia (main decision) granted the petitioner’s Petition for Review, reversing the CA and remanding the case to the RTC for further proceedings. This Concurring Opinion agrees with the ponencia’s ruling.

ISSUE

1. Whether the principle of res judicata applies to registration proceedings.
2. Whether Republic Act No. 11573 applies retroactively to this pending application for judicial confirmation of title.

RULING

1. No. Res judicata does not apply to registration proceedings as there is no conclusive adjudication of rights between adversarial parties in such cases.
2. Yes. RA 11573 shall be applied retroactively to this case. The law is curative in nature, intended to simplify the confirmation process for imperfect land titles. It shortens the required period of possession from “since June 12, 1945, or earlier” to “at least twenty (20) years immediately preceding the filing of the application.” It also simplifies the proof required for the land’s alienable and disposable status. Following the guidelines set in Republic v. Pasig Rizal Co., Inc., RA 11573 applies retroactively to all applications for judicial confirmation of title pending as of September 1, 2021, its effectivity date. This includes applications pending at the RTC or on appeal at the CA. The courts are directed to permit the presentation of additional evidence on land classification based on the new parameters. Given that the CA had found petitioner in possession of Lot No. 1341-A since around 1948, which would far exceed the new 20-year requirement, remanding the case for further proceedings to apply RA 11573 is in accord with justice.