Galvez v. Tuason
REITERATIONFacts
The Antecedents: Appellants, as heirs of the late Eladio Tiburcio, filed an action for the annulment of technical descriptions in Original Certificate of Title No. 735 and for the recovery of a parcel of land with an area of over 400 hectares, plus damages, against the Tuasons, the Register of Deeds of Rizal, the University of the Philippines (UP), and the People's Homesite and Housing Corporation (PHHC). Appellants alleged continuous possession as owners of the land. They discovered their property was included in OCT No. 735 in the name of the Tuasons, which was later cancelled and transferred to the Tuasons via a deed of donation, who then sold it to the UP and PHHC. Procedural History: Appellants' motion for a preliminary injunction was denied. The Register of Deeds was declared in default. PHHC and UP filed motions to dismiss the complaint for lack of sufficient cause of action and other grounds. The Court of First Instance of Rizal dismissed the complaint. The Petition: Appellants appealed the dismissal order to the Supreme Court.
Issue(s)
Whether the complaint states a sufficient cause of action against the UP and PHHC. Whether the cause of action is barred by prior judgment. Whether there is another action pending between the same parties for the same cause.
Ruling
The Supreme Court affirmed the order of dismissal issued by the Court of First Instance of Rizal. Dispositive Portion: WHEREFORE, the order appealed from is affirmed, with costs.
Ratio Decidendi
On the issue of whether the complaint states a sufficient cause of action against the UP and PHHC: The Court found that the lower court was correct in observing that the appellants' complaint lacked allegations that the UP and PHHC were purchasers in bad faith or with notice of any defect in their vendor's title. Without such allegations, the complaint was insufficient to constitute a cause of action against them. The record indubitably disclosed that the property claimed by appellants was a portion of a bigger parcel registered in the name of the Tuasons since 1914, and that the ownership of the property had been settled by prior court decisions. On the issue of whether the cause of action is barred by prior judgment (res judicata): The Court noted that the heirs of Eladio Tiburcio, through Marcelino Tiburcio, had previously filed an application for registration of the property based on a Spanish title, which was dismissed. This dismissal became final and executory. Furthermore, in 1957, Marcelino Tiburcio, for himself and the other heirs, filed Civil Case No. Q-2663 against PHHC and UP for reconveyance of the same lands, which was also dismissed and affirmed by the Supreme Court in G.R. No. L-13479. These prior judgments definitively settled the question of ownership and title to the property. On the issue of whether there is another action pending between the same parties for the same cause (lis pendens): Given the final and executory nature of the previous judgments concerning the ownership and title to the property, the principle of lis pendens, which requires another action pending between the same parties for the same cause, was rendered moot by the conclusive rulings in the prior cases. The question of ownership was thrice settled definitively and conclusively by the courts and was beyond the reach of review.
Main Doctrine
The dismissal of a complaint for lack of sufficient cause of action, based on grounds of res judicata and lis pendens, is proper when the issues of ownership and title to the property have been definitively settled by prior final and executory court decisions involving the same parties or their privies.