G.R. No. L-80294-95 September 21, 1988
CATHOLIC VICAR APOSTOLIC OF THE MOUNTAIN PROVINCE, petitioner, vs. COURT OF APPEALS, HEIRS OF EGMIDIO OCTAVIANO AND JUAN VALDEZ, respondents.

FACTS

The controversy originated from a 1962 land registration application filed by petitioner Catholic Vicar Apostolic of the Mountain Province (Vicar) over four lots in La Trinidad, Benguet. The Heirs of Juan Valdez and Egmidio Octaviano opposed the application for Lots 2 and 3. The land registration court confirmed Vicar’s title in 1965, but the Court of Appeals reversed this decision in CA-G.R. No. 38830-R on May 4, 1977, dismissing Vicar’s application for Lots 2 and 3. The Supreme Court subsequently denied both Vicar’s and the heirs’ separate petitions for review, making the 1977 CA decision final.
Following this, the heirs filed separate actions for recovery of possession in the Regional Trial Court. The trial court ruled in favor of the heirs, ordering Vicar to surrender the lots. Vicar appealed to the Court of Appeals, which affirmed the trial court’s decision. The appellate court held that the factual findings in the final 1977 CA decision—specifically that the heirs’ predecessors were possessors in good faith since 1906 and Vicar was merely a bailee in commodatum until it repudiated the trust in 1951—were binding under the principle of res judicata.

ISSUE

Whether the Court of Appeals correctly applied the principle of res judicata in barring the re-litigation of questions regarding ownership and possession of the subject lots based on its final 1977 decision.

RULING

Yes, the Supreme Court affirmed the Court of Appeals’ decision. The legal logic is anchored on the conclusive finality of the 1977 CA decision in CA-G.R. No. 38830-R. The core findings in that case—that the private respondents’ predecessors-in-interest possessed the lots under a claim of ownership in good faith from 1906, and that the petitioner Vicar held possession only as a bailee in commodatum, repudiating the trust only in 1951—constituted a final judgment on the merits regarding the parties’ rights over the property. These factual determinations are essential to the judgment and cannot be re-opened.
The principle of res judicata, specifically “conclusiveness of judgment,” bars the re-litigation of facts and issues already directly adjudicated in a former final judgment between the same parties. Since the Supreme Court had denied the petitions for review of that 1977 decision, it became immutable and executory. Therefore, the respondent Court of Appeals in the present recovery of possession cases correctly precluded Vicar from reasserting claims of ownership or acquisitive prescription, as the period of Vicar’s adverse possession was definitively established to have commenced only in 1951, which was insufficient for prescription. The prior final judgment governed the disposition of the subsequent cases.