CRESENCIO CANTILLANA and SALVACION LOCSIN, plaintiffs-appellants, vs. THE HEIRS OF FRANK D. SCOTT, defendants-appellees. (ANTONIO PEÑAFLOR, substituted).
FACTS
The land in controversy was adjudicated in favor of the heirs of Frank D. Scott (defendants-appellees) through final and executory decisions in Civil Cases Nos. 5475 (1931) and 6100 (1936), and Land Registration Case No. N-34 of the Court of First Instance of Albay. A decree and Original Certificate of Title were subsequently issued to them in 1964. On November 3, 1964, plaintiffs-appellants Cresencio Cantillana and Salvacion Locsin purchased the same land from Dominador Viray and Maria Tating, who derived their claim from predecessors-in-interest who were parties to the earlier litigation. The appellants took possession and introduced improvements. In 1966, a writ of possession was issued in favor of the appellees, leading to the appellants’ eviction.
In 1967, the appellants filed the present action (Civil Case No. 3508) for reconveyance and/or reimbursement for improvements and damages. They claimed ownership through acquisitive prescription, alleging possession by themselves and their predecessors for over 50 years. The defendants-appellees moved to dismiss on the ground of res judicata, citing the final judgments in the prior cases. The trial court granted the motion and dismissed the complaint, prompting this appeal.
ISSUE
Whether the trial court correctly dismissed the complaint for reconveyance on the ground of res judicata, and whether the alternative claim for reimbursement of improvements should proceed.
RULING
Yes, the doctrine of res judicata squarely applies to bar the action for reconveyance. For res judicata to apply, the following requisites must concur: (1) a final former judgment; (2) rendered by a court with jurisdiction; (3) a judgment on the merits; and (4) identity of parties, subject matter, and cause of action. The appellants conceded the presence of the first three requisites but contested the identity of parties.
The Court ruled that identity of parties exists. The appellants are not strangers but are successors-in-interest to the losing parties in the prior cases. Their own pleadings trace their title back to Alfredo Roa, who was a party in Civil Case No. 6100. As successors by title subsequent to the commencement of that action, they are bound by the judgment against their predecessors. The subject matter-the land itself-is also identical. Therefore, the action for reconveyance, which essentially seeks to relitigate ownership already settled with finality, is barred.
However, the Order of dismissal was reversed in part. The trial court’s dismissal was based solely on res judicata, which pertains only to the cause of action for reconveyance. It did not adjudicate the appellants’ alternative claim for reimbursement for the improvements they introduced on the land after their purchase in 1964, which is a separate and distinct cause of action. Whether they are builders in good faith and entitled to reimbursement under Articles 546 and 548 of the Civil Code is a factual matter requiring further proceedings.
The Supreme Court affirmed the dismissal of the complaint for reconveyance but remanded the case to the trial court for the sole purpose of receiving evidence and determining the merits of the claim for reimbursement of improvements and necessary expenses.
