G.R. No. 25660 , G.R. No. 32065, G.R. No. 33677 February 23, 1990
LEOPOLDO VENCILAO, ET AL., plaintiffs-appellants/petitioners, vs. TEODORO VANO, ET AL., defendants-appellees/respondents.

FACTS

These consolidated cases involve disputes over parcels of land in Bohol. In Land Registration Case No. 76, the heirs of Juan Reyes successfully registered the lands under Original Certificate of Title No. 400. Subsequently, numerous individuals (the Vencilao group) filed a complaint for reconveyance (Civil Case No. 1533), alleging they were the lawful owners by purchase or inheritance, possessing the lands publicly and adversely for over thirty years. They claimed the lands were included in the Reyes registration by mistake or fraud. The trial court initially denied the defendants’ motion to dismiss but later partially granted it, dismissing the cases of several plaintiffs on the ground of res judicata, as their claims were deemed barred by the prior final judgment in the land registration case.
In related proceedings, the Vencilao group was found guilty of contempt for disobeying a writ of possession issued in favor of the registered owners (the Ogilve/Luspo group). The trial court subsequently issued orders for the execution of the contempt finding and, critically, for the demolition of the houses of the petitioners to fully effectuate the writ of possession. The Vencilao group challenged these orders through petitions for certiorari.

ISSUE

The primary issues are: (1) Whether the trial court correctly applied res judicata to dismiss the reconveyance complaint of some plaintiffs; (2) Whether the trial court acted with grave abuse of discretion in ordering the demolition of the petitioners’ houses.

RULING

The Supreme Court affirmed the trial court’s rulings. On the first issue, the Court held that the doctrine of res judicata rightly barred the claims. A final judgment in a land registration case, which decrees the registration of land in the name of a person, conclusively settles the issue of ownership. The Vencilao group, who were parties or their privies in the earlier registration case, could not relitigate the matter through a subsequent action for reconveyance. The registration proceeding, being an action in rem, binds the whole world, and the decree of registration issued constitutes the best and conclusive evidence of title.
On the second issue, the Court found no grave abuse of discretion in the issuance of the demolition order. A writ of possession issued in a land registration proceeding is a ministerial duty of the court to place the successful registrant in possession of the property. The writ of demolition is a necessary complement to the writ of possession when structures erected by the defeated party prevent the registrant from fully enjoying possession. The Court cited Meralco vs. Mencias, stating that such a writ is reasonably necessary to do justice to the registered owner deprived of possession. The pendency of a separate petition (G.R. No. L-32065) challenging the execution of the contempt order did not bar the demolition, as that petition did not assail the writs of possession themselves. The demolition order was a logical enforcement of a final and executory judgment. The petitions were accordingly denied, and the temporary restraining order was lifted.