G.R. No. 248002. March 15, 2022
SEGUNDINA HELUHANO ARANO, PETITIONER, VS. DELILAH L. PULIDO, JOSELITO PULIDO, AND TEOFREDO PULIDO, RESPONDENTS.

FACTS

Rogaciana Roca inherited an unregistered property, Lot No. 1040. On March 30, 1965, she sold a 5,000-square-meter portion of it to Alfredo Pulido via a notarized Affidavit of Quitclaim. Upon Rogaciana’s death in 1988, her daughter, petitioner Segundina Heluhano Arano, inherited the remaining portion, Lot No. 1040-Part, and later sold a 500-square-meter portion to Spouses Pantao and Sacati Makaraya. On November 8, 2005, Alfredo Pulido filed a forcible entry case against Segundina and the Spouses Makaraya, which was decided in Alfredo’s favor. During a relocation survey for that case, Segundina learned that Lot No. 1040-Part had been segregated into Lot Nos. 1 and 2 (Lot No. 9134). Consequently, Segundina and the Spouses Makaraya filed a Complaint for Accion Publiciana/Recovery of Possession, and Annulment of Approved Subdivision/Segregation Plan against respondents Delilah, Joselito, and Teofredo Pulido (Alfredo’s children). They alleged that respondents unlawfully took possession of Lot Nos. 1 and 2 through fraud and stealth, and that the portion Alfredo bought was only on the eastern part of Lot No. 1040-Part. Respondents countered that they possessed the lots within the property bought by their father and an adjoining lot, their possession was peaceful until disturbed, and the issues were already resolved in the prior forcible entry case. The MTCC dismissed the complaint, finding respondents had prior possession and the complaint raised issues settled in the forcible entry case. The RTC affirmed, applying res judicata. The CA, while disagreeing on identity of causes of action for res judicata (bar by former judgment), affirmed based on conclusiveness of judgment, noting identity of parties and subject matter made the prior ruling on respondents’ prior possession conclusive. The CA also applied extraordinary acquisitive prescription to a 1,688-square-meter excess portion, finding respondents’ possession was actual, adverse, open, and uninterrupted for over 40 years. It further cited Article 1542 of the Civil Code, as the sale was for a lump sum with defined boundaries.

ISSUE

Whether the CA erred in affirming the dismissal of the complaint for Accion Publiciana/Recovery of Possession, and Annulment of Approved Subdivision/Segregation Plan.

RULING

The Supreme Court denied the petition and affirmed the CA’s rulings. The Court held that the CA correctly applied the principle of conclusiveness of judgment, as there was identity of parties and subject matter between the forcible entry case and the accion publiciana case, making the prior determination of respondents’ prior possession conclusive. The Court also upheld the CA’s application of extraordinary acquisitive prescription under Article 1137 of the Civil Code regarding the 1,688-square-meter excess area, as respondents’ possession was in the concept of an owner, actual, adverse, open, continuous, and uninterrupted for over 30 years (from 1965 to 2005), and the land was unregistered. Furthermore, the Court agreed that Article 1542 of the Civil Code applied because the sale was for a lump sum with specific boundaries, obligating the vendor to deliver all land within those boundaries. The Court emphasized that the resolution was limited to determining the better right of possession, not ownership.