GR L 17331; (November,1961) (Digest)
March 14, 2026GR L 27434; (September, 1986) (Digest)
March 14, 2026G.R. No. L-26504 February 20, 1973
HEIRS OF JOSE DOLLETON and HEIRS OF DIONISIO DOLLETON, petitioners, vs. THE HON. COURT OF APPEALS, and MARIA MAYUGA VDA. DE CAILLES, JOSE MAYUGA, CARMEN MAYUGA ABADEJOS, LOURDES MAYUGA BERNABE, MANUEL MAYUGA, and CONSOLACION MAYUGA DE LEON, respondents.
FACTS
This case originated from a 1930 land registration application by Eduardo C. Guico. Jose and Dionisio Dolleton opposed, claiming their lands were wrongfully included. The Court of Appeals, in a 1939 decision, ruled in favor of the Dolletons, confirming their ownership of specific portions and ordering that if they wished to register their lands, they must submit approved plans and share in the publication costs. This decision became final. Over twenty years later, in 1960, the heirs of the Dolletons filed a petition for the issuance of decrees based on the 1939 decision.
The Land Registration Commissioner reported that portions of the land adjudicated to the Dolletons were already inside Lot 10 of the original plan, for which a decree (No. N-60635) had been issued to Eduardo C. Guico in 1957. The petitioners amended their petition to seek annulment of this decree concerning those portions. Regarding another lot (Lot 2, Re-845), which was part of Lot 9 of the original plan, the respondents (the Mayugas) opposed the petitioners’ claim.
ISSUE
The primary issues were: (1) whether the decree of registration issued to Eduardo C. Guico should be annulled insofar as it included lands adjudicated to the Dolletons; and (2) whether the petitioners were entitled to the registration of Lot 2, Re-845, which was claimed by the Mayugas.
RULING
The Supreme Court affirmed the decision of the Court of Appeals. On the first issue, the petition for annulment of the decree issued to Eduardo C. Guico could not be entertained. The legal logic is rooted in procedural necessity: Eduardo C. Guico was not a party respondent in the case, either before the Supreme Court or the Court of Appeals. The only respondents were the Mayugas. Consequently, it was unnecessary and improper for the Court to adjudicate the merits of the annulment claim against a non-party. The Court explicitly declined to rule on whether the decree was wrongfully issued or whether the petition for its annulment was timely under the relevant law.
On the second issue, the Court upheld the Court of Appeals’ finding that the petitioners’ claim over Lot 2, Re-845 was without basis. The legal logic is based on the finality of the 1939 judgment. It was established that this lot was a portion of Lot 9, plan Psu-80886. The 1939 decision of the Court of Appeals had definitively adjudicated Lot 9 in favor of the heirs of Narciso Mayuga, the herein respondents. A final judgment is conclusive and constitutes the law of the case between the parties. Therefore, the petitioners could not claim ownership of a parcel that had already been awarded by final judgment to another party. The Supreme Court affirmed the award of Lot 9, including Lot 2 of Plan Re-845, to the Mayugas. The decision was without prejudice to any other action the Dolleton heirs might pursue regarding the lots included in Guico’s decree.
