G.R. No. L-20468 and L-20927, July 26, 1966
General Offset Press, Inc., plaintiff and appellee, vs. Apolonia Anatalio and Juan Federico, defendants and appellants. (G.R. No. L-20468)

Apolonia Anatalio and Juan Federico, petitioners and appellants, vs. General Offset Press Inc. and Hon. Mariano R. Virtucio, respondents and appellees. (G.R. No. L-20927)

FACTS

On May 7, 1960, General Offset Press, Inc. (GOP) filed an ejectment complaint against Apolonia Anatalio and Juan Federico in the Municipal Court of Quezon City. The defendants’ sole defense was their claim of ownership over the disputed land. The municipal court rejected this defense, sustained the complaint, and rendered a decision on November 15, 1960, directing the defendants to vacate. An order for immediate execution was issued. To restrain this execution, the defendants filed a petition for certiorari with preliminary injunction (Civil Case No. Q-5576) in the Court of First Instance (CFI) of Rizal, which granted a preliminary injunction on December 21, 1960. Simultaneously, the defendants appealed the municipal court’s decision to the same CFI (Civil Case No. Q-5541). The CFI rendered a joint decision on these two cases in favor of GOP, ruling that the defendants’ defense of ownership could not be entertained because GOP possessed a Torrens Title, the validity of which could not be assailed in an ejectment suit. This joint decision is the subject of the present appeal.
While their appeal from the municipal court was pending in the CFI, the appellants filed a separate action for quieting of title (Civil Case No. 5942) against GOP over the same land. The CFI dismissed this case on December 21, 1963. The appellants appealed to the Court of Appeals, which dismissed their appeal for failure to file their brief on time. They elevated this dismissal to the Supreme Court via a petition for certiorari (G.R. No. L-25598), which was also dismissed for being filed out of time. Consequently, the decision in the quieting of title case became final.
Following this finality, GOP filed a petition with the Supreme Court on April 4, 1966, to dismiss the instant appeal, arguing that the sole issue of ownership had become moot and academic. The Supreme Court granted this petition via a minute resolution on April 20, 1966. The appellants filed the instant motion for reconsideration.

ISSUE

Whether the Supreme Court correctly dismissed the present appeal (in the ejectment and related certiorari cases) as moot and academic due to the finality of the decision in the separate quieting of title case.

RULING

The Supreme Court denied the motion for reconsideration and affirmed the dismissal of the appeal. The Court held that with the dismissal of G.R. No. L-25598 (the appeal from the quieting of title case), the title and ownership of GOP over the disputed property, as against the appellants’ claim, became an established, settled, and incontestable fact. Consequently, the sole issue raised by the appellants in the present appeal—ownership—was rendered moot and academic. No useful purpose would be served by maintaining the appeal, as a decision on the merits in favor of the appellants would conflict with the final resolution in G.R. No. L-25598, and a decision in favor of GOP would yield the same result as dismissal. The Court further ruled that a dismissal on a technicality (such as being filed out of time) has the same effect and consequences as a dismissal on the merits for the purpose of rendering an issue final and settled.