G.R. No. 99843 June 22, 1993
Spouses BRAULIO ABALOS and AQUILINA ABALOS and JUANITO ULANDAY, petitioners, vs. COURT OF APPEALS, HEIRS OF ROMAN SORIANO, ELCOCADIO SORIANO and LIBRADA SORIANO, respondents.

FACTS

On August 16, 1979, spouses Braulio and Aquilina Abalos filed an application for registration of title over Lot No. 60052 and three-fourths (¾) pro-indiviso of Lot No. 8459. Roman Soriano opposed, claiming a one-seventh (¹/7) pro-indiviso share of the combined areas. The lots were originally owned by Adriano Soriano. Upon his death, his heirs executed an extrajudicial partition, dividing the property into northern and southern portions. The northern portion went to Candido, Lourdes, and the heirs of Dionesia, and the southern portion was declared in the names of Roman, Francisca, Librada, and Elcocadio. In 1971, Candido, Lourdes, and the heirs of Dionesia sold their shares in the northern portion to the Abalos spouses. Lourdes, Librada, and Francisca also sold their three-fourths (¾) shares of the southern portion to the Abalos spouses. The land registration court granted the application for registration on June 27, 1983, confirming the Abalos spouses’ title over Lot No. 60052 and the three-fourths (¾) of Lot No. 8459, and Roman Soriano’s title over one-fourth (¼) of Lot No. 8459. Roman Soriano appealed to the Intermediate Appellate Court, which affirmed the decision. The Supreme Court denied his petition for review. On July 15, 1983, Roman Soriano, Elcocadio Soriano, and Librada Soriano filed a complaint (Civil Case No. 15958) against the Abalos spouses for annulment of document and/or redemption, ownership, and damages. The Abalos spouses moved to dismiss on the ground of res judicata, among others. The trial court initially dismissed the re-amended complaint but later reconsidered and set aside the dismissal. The Abalos spouses filed a petition for certiorari and prohibition with the Court of Appeals, which dismissed the petition, ruling that the land registration court had limited jurisdiction and could not pass upon the validity of contracts. The Supreme Court reversed the Court of Appeals.

ISSUE

Whether the principle of res judicata bars the subsequent civil action (Civil Case No. 15958) for annulment of document and/or redemption, ownership, and damages, considering that the validity of the deeds of sale and ownership of the properties had already been litigated and adjudicated in the prior land registration case.

RULING

Yes. The Supreme Court reversed the decision of the Court of Appeals and ordered the dismissal of Civil Case No. 15958. The Court held that while a land registration court exercises special and limited jurisdiction, it may determine conflicting claims of ownership under certain exceptions, such as when the parties have acquiesced in submitting the issues for determination, were afforded full opportunity to present evidence, and the court considered sufficient evidence. In the land registration case, the parties actively litigated the validity of the deeds of sale and ownership. Elcocadio and Librada Soriano even testified before the land registration court assailing the validity of the sale. The land registration court’s decision, which was affirmed by the appellate courts, necessarily ruled on the validity of the conveyances to adjudicate the titles. Therefore, the subsequent civil action involving the same parties, subject matter, and issues is barred by res judicata. The Court also noted that the right of legal redemption under Article 1620 of the Civil Code was not available because the property had been partitioned and was no longer held pro-indiviso at the time of the sale.