G.R. No. L-48050 October 10, 1994
FELICIDAD JAVIER, petitioner, vs. HON. REGINO T. VERIDIANO II, Presiding Judge, Branch I, Court of First Instance of Zambales and REINO ROSETE, respondents.

FACTS

Petitioner Felicidad Javier filed a complaint for forcible entry (Civil Case No. 926) before the City Court of Olongapo in December 1970, alleging that Ben Babol forcibly dispossessed her of a 200-square-meter portion of Lot No. 1641. The city court dismissed the complaint, finding the disputed area to be outside Lot No. 1641 based on a Bureau of Lands report. This decision was affirmed by the Court of First Instance and became final in April 1973. Subsequently, in December 1973, Javier was granted a sales patent and issued Original Certificate of Title No. P-3259 covering Lot No. 1641. Babol later sold the property, including the disputed portion, to Reino Rosete.
In June 1977, Javier filed a complaint for quieting of title and recovery of possession (Civil Case No. 2203-0) against Babol and Rosete before the Court of First Instance, asserting her ownership by virtue of the issued title. Rosete moved to dismiss on the ground of res judicata, arguing the prior forcible entry case barred the new action. The trial court granted the motion, dismissing the complaint. Javier appealed, contending there was no identity of parties or causes of action between the two cases.

ISSUE

Whether the final judgment in the prior forcible entry case constitutes res judicata to bar the subsequent action for quieting of title.

RULING

No, res judicata does not apply. The Supreme Court reversed the trial court’s dismissal. For res judicata to bar a subsequent action, there must be, among other requisites, identity of parties and identity of causes of action. Here, there was no identity of causes of action. The first case was an accion interdictal (forcible entry), a summary action concerned solely with the issue of prior physical possession. The judgment therein determined only who had a better right of possession, not ownership. The second case was an accion reivindicatoria (recovery of ownership) coupled with an action to quiet title, which seeks to establish ownership based on a Torrens title and recover possession as an incident of that ownership. These are distinct causes of action with different purposes and requisites. Furthermore, the Court noted that the issuance of the Torrens title to Javier after the finality of the ejectment case constituted a supervening event that could alter the rights of the parties regarding ownership. The petition was granted, and the case was remanded for trial.