G.R. No. L-33850 January 22, 1976
DEMETRIO MANALO, petitioner, vs. HON. HERMINIO C. MARIANO, as Presiding Judge of the Court of First Instance of Rizal, SEVERINO, INOCENCIO, PRISCILLA, TEODORA, ELENA and LOPEZ all surnamed MANALO, respondents.

FACTS

Demetrio Manalo filed a land registration application for several lots based on partition agreements executed in 1952 and 1960 with his nephew, Severino Manalo. The case was assigned to Branch VIII of the CFI of Rizal. Severino opposed, claiming his signature on the 1960 “Kasulatan ng Hatian ng Lupa” was obtained by fraud. After trial, Branch VIII rendered a decision on October 9, 1970, finding the partition valid and decreeing registration in Demetrio’s name. The court specifically rejected the fraud claim, noting Severino did not testify and his son’s testimony was not credible. This decision became final.
Subsequently, Severino’s children (excluding Severino himself) filed a separate action in Branch X of the same CFI seeking annulment of the same 1960 partition on identical grounds of fraud. Demetrio moved to dismiss, arguing the action was barred by the prior judgment in the land registration case. Branch X denied the motion, ruling that the land registration court had limited jurisdiction and that res judicata did not apply because Severino did not personally testify in the prior case.

ISSUE

Whether the action for annulment of the partition agreement filed in Branch X is barred by res judicata due to the final judgment in the prior land registration case decided by Branch VIII.

RULING

Yes, the action is barred by res judicata. The Supreme Court granted the petition for certiorari and prohibition, holding that the prior land registration decision constitutes a bar to the subsequent annulment case. A land registration proceeding is an action in rem, and its decision is conclusive upon the title to the land and binding upon the whole world. In this instance, the decision also operates as a judgment in personam against Severino Manalo, who was the formal oppositor in the case. He actively participated, presented evidence through his son to prove the alleged fraud, and sought registration of the lots in his own name. The court in Branch VIII directly ruled on the validity of the partition agreement, finding it to be executed without fraud.
All elements of res judicata are present: (1) a final judgment rendered by a court of competent jurisdiction (Branch VIII); (2) the judgment is on the merits, having resolved the issue of fraud; and (3) there is identity of parties, subject matter, and cause of action between the two cases. The parties in the annulment suit are the children of Severino, who are in privity with him as his successors-in-interest. The subject matter is the same partition agreement, and the cause of action—its annulment based on fraud—is identical to the issue already litigated and resolved in the registration case. Therefore, Branch X acted without jurisdiction in entertaining the annulment suit, as the matter had been settled with finality.