Olaes v. Tanda
REITERATIONFacts
The Antecedents: Teodoro Tanda executed a deed of sale a retro in favor of Narciso Aldaya. Tanda later adjudicated the property to himself as the sole heir of his parents and subsequently sold it via pacto de retro to Aldaya. Angel S. Olaes acquired the land from Aldaya after Aldaya consolidated his ownership. Procedural History: This case represents the sixth and seventh time Teodoro Tanda has resorted to the Supreme Court in his efforts to nullify the deed of sale a retro. Previous attempts involved appeals upholding the validity of the sale, dismissal of actions based on res judicata, petitions for certiorari and appeals from orders denying relief, and petitions to compel the allowance of appeals, all of which were dismissed. The Petition: In G.R. No. L-21919, Angel S. Olaes petitioned the Court of First Instance of Cavite for the cancellation of an encumbrance and a notice of lis pendens annotated on his certificate of title. The encumbrance was for the rights of legal heirs or creditors of Tanda's deceased parents, and the lis pendens was annotated at the instance of the plaintiffs in a previous civil case. In G.R. No. L-21920, the same appellants questioned orders authorizing the clerk of court to tax costs and denying their petition for relief.
Issue(s)
Whether the land registration court had jurisdiction under Section 112 of Act 496 to cancel the two-year encumbrance and notice of lis pendens despite the appellant's objection. Whether the Clerk of Court of the Court of First Instance (CFI) had the authority to tax the treble costs imposed by the Supreme Court. Whether the appellant could re-litigate the validity of the pacto de retro sale based on alleged fraud.
Ruling
The Supreme Court affirmed the appealed orders in both G.R. No. L-21919 and G.R. No. L-21920. Treble costs were imposed against Teodoro Tanda personally in each case.
Ratio Decidendi
On Issue 1: The Court ruled that the land registration court acted within its jurisdiction under Section 112 of Act 496. While the appellant cited cases suggesting that consent or unanimity is required for such petitions, the Court found those cases inapplicable because the objection raised by Tanda was not 'serious.' The Court emphasized that eighteen years had passed since Tanda adjudicated the property to himself without any other heirs or creditors instituting claims; therefore, the two-year reservation under the Rules of Court was no longer necessary. Additionally, the notice of lis pendens was ripe for cancellation because the underlying litigation had been finally and executory resolved by the Supreme Court in previous appeals. On Issue 2: The Court held that the Clerk of the Court of First Instance (CFI) was the proper officer to tax the costs. Pursuant to Section 8, Rule 142 of the Revised Rules of Court, the clerk of the court to which the records have been remanded is tasked with the taxation of costs. The Court noted that the Clerk of the Supreme Court did not tax the treble costs because the records had already been transmitted back to the trial court at the time the winning party submitted its bill of costs. Thus, the lower court's clerk acted in conformity with the rules in taxing the P150.00 treble costs. On Issue 3: The Court flatly refused to consider the merits of the pacto de retro sale, declaring the matter res judicata. The validity of the sale had been affirmed by the Court as early as 1951 in G.R. No. L-3278 and reaffirmed in multiple subsequent resolutions across different case numbers. The Court described Tanda's attempt to revive issues of fraud and the value of Japanese war notes as 'impertinent' and 'vexatious.' By bringing the same settled issues to the Court for the sixth and seventh time, Tanda was deemed to have abused the judicial process, justifying the imposition of treble costs against him personally to deter further meritless litigation.
Main Doctrine
The Supreme Court reiterated that issues already decided with finality in previous litigations between the same parties, involving the same subject matter, constitute res judicata and cannot be revived. Furthermore, the Court affirmed that the Clerk of Court can validly tax costs, even if imposed by the Supreme Court, when the records have been remanded to the lower court.