G.R. No. L-31568 & L-31569, March 19, 1930
JULIAN SANTIAGO, ET AL. vs. PEDRO SANTOS, ET AL. and PEDRO SANTOS Y BAUTISTA vs. JULIAN SANTIAGO, ET AL.

FACTS

Two consolidated land registration cases involve the same parcel of land in Hagonoy, Bulacan. In G.R. No. 31568, Julian Santiago and others applied for registration, opposed by Pedro Santos and others. In G.R. No. 31569, Pedro Santos applied for registration, opposed by Julian Santiago and others. The land was previously subject to two prior lawsuits between the same (1) an unlawful detainer case (G.R. No. 12208) filed by Santos against Santiago, decided by the Supreme Court on September 9, 1918, ordering Santiago to restore possession to Santos; and (2) an action for recovery of real property filed by Santiago against Santos, decided by the Supreme Court on December 31, 1925 (G.R. No. 24003), affirming the dismissal of Santiago’s complaint. During the pendency of the second case, Santos partitioned the land, transferring half to Eugenia Rivera and Severina Buzon. In the registration proceedings, both parties claimed ownership and possession.

ISSUE

Whether the prior judgments in the unlawful detainer case and the recovery of real property case constitute res judicata, barring relitigation of the issues of possession and ownership in the present registration proceedings.

RULING

Yes. The Supreme Court affirmed the lower court’s judgment, dismissing Santiago’s application and decreeing registration of the land in favor of Santos and his transferees. The Court held that the doctrine of res judicata applies.

1. On Possession: The decision in the unlawful detainer case (G.R. No. 12208) is res judicata on the issue of possession. The land subject of that case is the same land in controversy, identified by its boundaries (creeks and rivers), not merely its area. Santiago’s claim that it was a different parcel was untenable, as his own complaint in the recovery case described it as the same land involved in the detainer case.

2. On Ownership: The decision in the recovery of real property case (G.R. No. 24003) is res judicata on the issue of ownership. The ownership of the land was the very essence of that controversy, which is the same basis for Santiago’s claim in the registration proceeding. Under the prevailing doctrine, a judgment operates as a bar not only to matters actually litigated but also to all matters that could have been litigated in the prior action upon the same claim. The Court cited Peñalosa vs. Tuason and Palanca Tanguinlay vs. Quiros, emphasizing that a party cannot escape res judicata by varying the form of action or seeking a different remedy for the same cause of action.

Thus, both prior judgments are conclusive between the parties, precluding relitigation of possession and ownership. The registration decree was properly issued in accordance with these settled rights.