GR L 19940; (August, 1965) (Digest)
G.R. No. L-19940, L-19941, L-19942, L-19943, L-19944 August 14, 1965.
Fernandez Kidpalos, Waldo Kidpalos, Nabos Valenciano, Maglia Cayapa, Sando Lampacan, Basaten Lampacan, Consing Lampacan and Topayna Lampacan, applicants-appellants, vs. Baguio Gold Mining Company, oppositor-appellee.
FACTS
The applicants-appellants previously filed a reivindicatory action (Civil Cases Nos. 457, 458, 460, 463 and 549) against Baguio Gold Mining Company and the Director of Mines in the Court of First Instance of Baguio City, seeking a declaration of ownership over certain parcels of land, annulment of the mining company’s overlapping mineral claims, damages, and injunctive relief. The trial court dismissed the suits, finding the plaintiffs failed to substantiate their ownership claims. On appeal, the Court of Appeals affirmed the dismissal, finding the land was part of the public domain (Cordillera Forest Reservation) and that the Baguio Gold Mining Company had acquired a superior title to the mineral claims through valid locations and occupation since the 1920s, subsequently validated by law. The Supreme Court, in G.R. Nos. L-16649 to L-16653, dismissed the petitioners’ appeal, noting the issues were factual and without merit, but stated its resolution was “without prejudice to the registration proceedings filed by petitioner before the same court regarding the properties herein involved.” While the reivindicatory cases were on appeal, the appellants filed the present land registration applications for the same properties. After the Supreme Court’s resolution became final, the Baguio Gold Mining Company moved to dismiss the registration cases on the ground of res judicata. The Court of First Instance of Baguio City granted the motions and dismissed the applications.
ISSUE
Whether the doctrine of res judicata bars the present land registration applications filed by the appellants.
RULING
Yes. The Supreme Court affirmed the order of dismissal on the ground of res judicata. The Court held that there is identity of parties, subject matter, and cause of action between the previous reivindicatory suits and the present registration proceedings. Although the forms of action differ (one being reivindicatory and the other for registration), this difference is irrelevant for res judicata, as both actions fundamentally assert the appellants’ ownership of the same land against the claim of the mining company. The final judgment of the Court of Appeals in the prior cases, which found the mining company’s title superior and dismissed the appellants’ claims, was rendered on the merits and conclusively settled the issue of ownership. The Supreme Court’s prior “without prejudice” clause in its resolution merely indicated that the reivindicatory judgment did not automatically decide the pending registration cases; it did not preclude the mining company from raising res judicata as a defense in those separate proceedings. The doctrine of res judicata extends not only to the dispositive portion of a judgment but also to all facts and issues that were necessarily determined and are the groundwork of the decision. The finding of the mining company’s superior title was the basis for the dismissal in the first action and thus concludes the parties. The change in the law regarding the period of possession required for registration does not benefit the appellants, as the vesting of title in the mining company effectively interrupted any possession they claimed.
