G.R. No. L-7910; October 1, 1913
NICOLAS MARIANO, SR., ET AL., plaintiffs-appellees, vs. GREGORIO PURUGANAN, ET AL., defendants-appellants.

FACTS:
This case arose from the execution of a final judgment in a prior action for recovery of possession ( G.R. No. 8 Phil. 519). In that prior case, Cirilo Puruganan (predecessor of the herein defendants-appellants) successfully sued to recover six parcels of land from certain defendants, based on a recorded title of composition with the State. The Supreme Court affirmed the judgment. Upon execution in August 1908, the sheriff, with the aid of the original surveyor, delivered possession of the lands to Puruganan after verifying their identity and area.

Two years later, in October 1910, Nicolas Mariano, Sr. and 18 others (plaintiffs-appellees) filed the present suit against the heirs of Cirilo Puruganan. They sought to annul the prior delivery of possession and to recover the same lands, alleging that the properties delivered under the writ of execution were not the lands described in Puruganan’s title but were instead the plaintiffs’ own lands. The Court of First Instance ruled in favor of the plaintiffs, ordering the Puruganan heirs to deliver the lands.

ISSUE:
Whether the lands delivered to Cirilo Puruganan pursuant to the final judgment in the prior case are the same lands described in his title and covered by the writ of execution, or whether they are different lands belonging to the new plaintiffs (Mariano, et al.).

RULING:
The Supreme Court REVERSED the judgment of the lower court and ABSOLVED the defendants-appellants (Puruganan heirs) from the complaint.

The Court held that the identity of the lands had already been conclusively settled in the prior case, which constituted res judicata. The sheriff’s return of the writ of execution demonstrated that the area of the lands delivered matched exactly the area specified in Puruganan’s title, complaint, and the writ itself. The fact that some of the boundaries mentioned in the sheriff’s return differed from those in the title (due to changes in adjacent landowners over time) did not alter the identity of the parcels, as the area remained the same.

The Court found the testimony of the plaintiffs’ witnesses (who were defendants in the prior case) claiming that Puruganan took possession of other lands to be unworthy of credence. If their claim were true, the area delivered would have exceeded that stated in the title, which was not the case. Against Puruganan’s lawful and registered title of ownership, the plaintiffs’ claim based merely on alleged possession, unsupported by any title of acquisition, could not prevail. The action was essentially an impermissible collateral attack on a final judgment and a registered title.