G.R. No. L-39899 December 29, 1983
ARSENIO DELA CRUZ, PEDRO SANGABOL and LUCIA GUTIERREZ, petitioners, vs. HON. VIRGILIO D. POBRE YÑIGO who took over and replaced the HON. FLORENDO P. AQUINO, Judge of the Court of First Instance of Nueva Ecija, and POTENCIANO REAÑO, respondents.

FACTS

The petitioners are the registered owners of three lots (Lots 1896, 1913, and 1914 of the Sta. Rosa Cadastre), having acquired them through a valid homestead patent and subsequent transfer certificates of title issued as early as 1956. In 1966, private respondent Potenciano Reaño filed a “Petition for Continuation of Cadastral Proceedings” over the same properties. The cadastral court, without notice to the petitioners who were already registered owners, adjudicated the lots to Reaño and issued a writ of possession. The petitioners challenged this in G.R. No. L-29792 (Dela Cruz v. Reaño, 34 SCRA 585), where the Supreme Court, in a 1970 decision, granted certiorari and annulled the writ of possession, declaring it of no legal effect. Despite this final Supreme Court ruling, Reaño persisted with the cadastral proceedings before a different judge, who subsequently issued another decision in 1974 again adjudicating the identical lots to Reaño. The petitioners thus filed the instant petition to nullify this subsequent decision and related orders.

ISSUE

Whether the respondent judge committed grave abuse of discretion in rendering a new decision adjudicating the same properties to Reaño, thereby disregarding the final and executory judgment of the Supreme Court in G.R. No. L-29792.

RULING

Yes. The Supreme Court granted the petition, nullifying the subsequent cadastral decision and orders. The legal logic is anchored on the doctrine of finality of judgment and the principle of conclusiveness of judgment or res judicata. The 1970 decision in G.R. No. L-29792 was a final adjudication on the merits regarding the ownership and titling of the disputed lots, having conclusively ruled in favor of the petitioners and against Reaño’s claims. Once a Supreme Court decision becomes final, it is immutable and unalterable. No court, including the court of origin, can modify, evade, or re-litigate the settled issues. The respondent judge’s act of issuing a new decision contravening the final Supreme Court ruling constituted a blatant disregard of a superior court’s authoritative pronouncement, which is a grave abuse of discretion. The Court emphasized that its role is to speak with finality on legal controversies, and all lower courts are bound to obey and defer to its decisions. The subsequent cadastral proceedings were a mere reiteration of claims already definitively resolved, making the new decision void for violating the settled rule that when the Supreme Court has spoken, its judgment is the law of the case binding on all.