Pajomayo v. Manipon
REITERATIONFacts
The Antecedents: Plaintiffs-appellees, heirs of Diego Pajomayo, alleged they are co-owners of a parcel of land covered by Original Certificate of Title (OCT) No. 1089, inherited from their father, who had possessed the land for over 70 years. They claimed defendants-appellants dispossessed them in 1956, causing damages. Defendants-appellants claimed exclusive ownership of a parcel of land covered by OCT No. 14034, issued in cadastral proceedings, also claiming inheritance and 70 years of possession. They alleged improvements worth P1,000.00 and raised defenses of res judicata and prescription. Procedural History: The parties submitted a stipulation of facts, agreeing that the land was covered by two titles: OCT No. 1089 in the name of Diego Pajomayo (plaintiffs' predecessor) and OCT No. 14034 in the name of Rodrigo Manipon (defendant). The Court of First Instance of Pangasinan ruled in favor of the plaintiffs, declaring Diego Pajomayo the lawful owner, ordering defendants to vacate, and directing the cancellation of OCT No. 14034. The Petition: Defendants appealed the decision, assigning errors related to the nullification of their title, failure of plaintiffs to prove their cause of action, and the non-application of res judicata.
Issue(s)
Whether the lower court erred in declaring Original Certificate of Title No. 14034 null and void. Whether the lower court erred in ordering the defendants to vacate the land and deliver possession to the plaintiffs. Whether the lower court erred in not applying the doctrine of res judicata.
Ruling
The decision of the lower court is affirmed. Defendants-appellants are ordered to vacate the land in question and deliver possession thereof to the plaintiffs-appellees. Original Certificate of Title No. 14034 is ordered cancelled.
Ratio Decidendi
On the validity of OCT No. 14034 and the order to vacate: The Court held that the identity of the land was not in question, and the sole issue was which of the two titles should prevail. It affirmed the lower court's finding that OCT No. 1089, issued on November 27, 1931, in virtue of a free patent granted to Diego Pajomayo, should prevail over OCT No. 14034, issued on April 1, 1957, in connection with cadastral proceedings. The Court reiterated the principle that a decree of registration issued in cadastral proceedings does not have the effect of annulling a title previously issued in accordance with the Land Registration Act. Therefore, the cancellation of OCT No. 14034 and the order to vacate were correct. On the application of res judicata: The Court found that the doctrine of res judicata could not be applied in favor of the defendants. The plaintiffs based their claim on OCT No. 1089, issued in 1931, while the defendants' claim was based on OCT No. 14034, issued in 1957. For res judicata to apply, there must be a prior judgment between the same parties involving the same subject matter and cause of action. In this case, the earlier title, OCT No. 1089, was issued based on a free patent and its registration, which automatically brought the land under the operation of the Land Registration Act, giving it the force of a Torrens Title. The subsequent cadastral proceedings could not re-adjudicate land already registered under the Torrens system. On the superiority of the earlier title: The Court emphasized that when two certificates of title are issued to different persons covering the same land, the earlier in date must prevail. This principle is firmly established in Philippine jurisprudence. The registration of the homestead patent under Section 122 of the Land Registration Act (Act 496) made the land registered land, and the certificate of title issued had the force and effect of a Torrens Title. Subsequent registration or adjudication in cadastral proceedings could not divest the rights of the holder of the prior, valid title. The operative act to convey and affect the land is registration, and the earlier registration under a valid title takes precedence.
Main Doctrine
Where two certificates of title are issued to different persons covering the same land, the earlier in date must prevail. A certificate of title issued by virtue of a registered homestead patent has the force and effect of a Torrens Title and cannot be subject to inquiry in subsequent cadastral proceedings.