GR L 6669; (May, 1954) (Digest)
G.R. No. L-6669; May 3, 1954
Pedro Daquis, plaintiff-appellant, vs. Maximo Bustos, ET AL., defendants-appellees.
FACTS
On September 21, 1921, Homestead Patent No. 3236 was issued to Pedro Daquis, covering Lot No. 1662, and Original Certificate of Title No. 1073 was issued on November 6, 1921. On September 6, 1926, Daquis conveyed the lot by absolute sale to Maximo Bustos. The next day, Bustos filed a cadastral answer claiming ownership by virtue of the purchase and, with Daquis’s approval, declared the property for tax purposes in his name. On November 18, 1932, Judge Enrique V. Filamor of the Court of First Instance of Nueva Ecija issued an order in the cadastral proceedings, pursuant to which the Register of Deeds cancelled Daquis’s title and issued Transfer Certificate of Title No. 8310 to Bustos and his wife on June 30, 1934. On September 24, 1952, Daquis filed a complaint seeking cancellation of the transfer documents and title, declaration of his ownership, and damages, alleging the sale violated Section 116 of Act No. 2874 as it occurred within five years from the patent’s issuance. The defendants moved to dismiss based on res judicata and the statute of limitations. The trial court dismissed the complaint.
ISSUE
Whether the trial court erred in dismissing the complaint on the grounds that the action is barred by a prior judgment (res judicata) and the statute of limitations.
RULING
The order of dismissal is affirmed. The court held that the decision of Judge Filamor in the cadastral proceedings, rendered on November 18, 1932, which recognized the sale and led to the issuance of a new title to Bustos, became final long before Daquis filed his complaint in 1952. Even assuming the sale was erroneously declared valid for occurring within the prohibited five-year period, such error was not jurisdictional and could only have been corrected by a timely appeal. The prior cadastral decision constitutes res judicata, and the action is barred by the statute of limitations, having been filed more than twenty years after that decision became final. Litigations must end, and titles cannot be reopened indefinitely.