G.R. No. L-24114; August 16, 1967
PEOPLE’S HOMESITE AND HOUSING CORPORATION and UNIVERSITY OF THE PHILIPPINES, petitioners, vs. HON. EULOGIO MENCIAS, Judge of Court of First Instance of Rizal, ELPIDIO TIBURCIO, JOSE SALVADOR, SIMPLICIO SALVADOR, MARCOS SALVADOR, PIO TIBURCIO, PETRONILO TIBURCIO, EMETERIO TIBURCIO, EULALIO TIBURCIO, VERONICA TIBURCIO, DONATA TIBURCIO, MARGARITA TIBURCIO, CARMEN TIBURCIO, SEGUNDA TIBURCIO, ET AL., respondents.

FACTS

This is an original petition for certiorari and prohibition with preliminary injunction filed by the People’s Homesite and Housing Corporation (PHHC) and the University of the Philippines (U.P.) against Judge Eulogio Mencias and private respondents, most surnamed Tiburcio. The petition stemmed from five orders issued by the respondent judge in Civil Case No. 5572, where the private respondents (the Tiburcios) sought the annulment of Original Certificates of Title (OCT) 730 and 735 in the name of the Tuasons, and Transfer Certificates of Title (TCT) 16263, 9462, and 1356 in the names of Varsity Hills, Inc., U.P., and PHHC, respectively, plus damages. The Tiburcios claimed ownership of about 430 hectares of land in Quezon City based on a Spanish title from 1877 in the name of Eladio Tiburcio, alleging continuous possession. They asserted that the U.P., PHHC, and Varsity Hills, Inc. intruded upon the land in 1955. They further alleged that OCTs 730 and 735 were null and void due to various irregularities, including the use of detachable sheets for technical descriptions, incomplete entries, and the absence of records for the corresponding decrees.
The PHHC and U.P. filed motions to dismiss the complaint on grounds including bar by prior judgment, pending another action, prescription/laches, insufficiency of cause of action, misjoinder, lack of jurisdiction, and improper venue. In an order dated June 1, 1961, the respondent judge denied the motions regarding venue and jurisdiction, holding other grounds in abeyance. Subsequent orders dated March 30, 1963, and June 5, 1963, granted a preliminary injunction against PHHC. Orders dated July 20, 1965, and September 28, 1965, denied the petitioners’ motions to dismiss which cited the Supreme Court’s decision in Galvez, et al. vs. Tuason, et al., G.R. No. L-15644, February 29, 1964. The petitioners contend these orders were issued without or in excess of jurisdiction or with grave abuse of discretion.

ISSUE

Whether the respondent court acted without or in excess of jurisdiction or with grave abuse of discretion in issuing the challenged orders, particularly in denying the petitioners’ motions to dismiss the complaint, in light of the Supreme Court’s prior decision in Galvez and Tiburcio vs. Tuason, et al..

RULING

Yes. The Supreme Court granted the petition. It held that the respondent court abused its discretion in not dismissing the complaint against U.P. and PHHC. The Court ruled that the cause of action was barred by prior judgment, laches, and prescription, citing its previous decisions in Galvez and Tiburcio vs. Tuason, et al. (G.R. No. L-15644) and Tiburcio, et al. vs. PHHC (G.R. No. L-13479). In those cases, the Court had already definitively ruled on the validity of the titles in question and upheld U.P. and PHHC as the owners of the lands covered by TCTs 9462 and 1356. These prior rulings constitute the “law of the case,” which is binding on all inferior courts. The respondent judge’s persistence in maintaining his orders after being apprised of the Galvez decision compounded the abuse of discretion.
Accordingly, the Supreme Court:
1. Annulled and set aside the five challenged orders.
2. Made permanent the writ of preliminary injunction it had issued on July 24, 1967.
3. Ordered the respondent court to dismiss the reamended complaint as against petitioners U.P. and PHHC.
4. Ordered all private respondents to withdraw their application for approval of Survey Plan SWO-40888 from the Bureau of Lands and to cancel all existing subdivision plans respecting the land covered by TCTs 9462 and 1356.
Copies of the decision were ordered forwarded to the relevant Register of Deeds and the Director of the Bureau of Lands.