Dacasin v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and possession of a parcel of rural land in Pangasinan. Jose Maramba initially possessed the land. In 1943, Sabina Capua and companions took possession. Maramba filed a revindicacion suit (Civil Case No. 895) against Capua, which was pending for years. During this litigation, Sabina Capua sold the property to Gualberto Calulot in 1950. A decision in Civil Case No. 895 in 1952 declared Jose Maramba the owner, but this judgment was not executed within the statutory period. Subsequently, Gualberto Calulot sold the land to Felipe Capua and Sinforosa Padilla in 1960. After Jose Maramba's death, his heirs sold the property to Juan Dacasin. 2. Procedural History: The current case originated as Civil Case No. 1455, filed by Felipe Capua and others against Juan Dacasin and the heirs of Jose Maramba, seeking a declaration of ownership based on their purchase and continuous possession. The Court of First Instance of Pangasinan ruled in favor of the defendants (Dacasin et al.), declaring Juan Dacasin the lawful owner. The plaintiffs appealed this decision to the Court of Appeals. The Court of Appeals reversed the trial court's judgment, adjudicating ownership to the plaintiffs (Capua et al.) and making a preliminary injunction permanent. The defendants (Dacasin et al.) then filed the present petition for review on certiorari with the Supreme Court. 3. The Petition: The petitioners, Juan Dacasin and the heirs of Jose Maramba, seek review of the Court of Appeals' decision. Their petition argues that the appellate court erred in reversing the trial court's judgment. The core of their argument is that the issue of ownership was already settled by res judicata in Civil Case No. 895, which declared Jose Maramba the owner. They contend that the Court of Appeals improperly allowed the claim of acquisitive prescription by Felipe Capua, overlooking the interruption of possession due to the earlier litigation and the failure to register their titles. The petitioners assert that the trial court correctly applied the principle of res judicata and found their predecessor-in-interest to be the true owner.
Issue(s)
Whether the possession of the respondents and their predecessors-in-interest was sufficient to acquire the property through acquisitive prescription despite the pendency of a revindication suit. Whether the respondents possessed the property in the 'concept of owner' as required by law for prescription. Whether the registered deeds of the petitioners prevail over the unregistered deeds of the respondents.
Ruling
The judgment of the respondent Court of Appeals is hereby reversed, and the decision of the Court of First Instance of Pangasinan in Civil Case No. 1455 is affirmed, with costs against the respondents. Petition granted.
Ratio Decidendi
On Issue 1: The Supreme Court held that the possession of Sabina Capua was civilly interrupted by the judicial summons in Civil Case No. 895 filed on September 8, 1944. Applying Article 1123 of the New Civil Code (NCC), the Court clarified that during the pendency of the litigation from 1944 until the judgment in 1952, the land was in custodia legis and the prescriptive period did not run. The successor-in-interest, Gualberto Calulot, who purchased the property pendente lite in 1950, could not tack his possession to that of Sabina because her possession was already interrupted and she eventually lost the litigation. Consequently, there was a gap in the continuity of the occupancy required for prescription, making the respondent's claim of seventeen years of uninterrupted possession legally untenable. On Issue 2: The Court ruled that the respondents failed to prove they possessed the land in the concept of an owner. Evidence showed that even after the sales to Calulot (1950) and Felipe Capua (1960), the tax declarations remained in the name of the original usurper, Sabina Capua. The Court emphasized that the failure of the vendees to cancel the tax declaration in the vendor's name and declare it in their own names leads to the inevitable conclusion that they did not deem themselves owners. Since possession in the concept of owner is an essential requisite for acquisitive prescription, the occupancy by Calulot and Capua remained mere possession without the necessary legal character to ripen into ownership. On Issue 3: The Court found that the petitioners held registered deeds of sale, whereas the respondents relied on unregistered instruments. Under Article 709 of the New Civil Code, titles of ownership duly inscribed in the Registry of Property constitute notice to third persons and afford protection to those who rely on them in good faith. The rule of caveat emptor requires a purchaser to check the vendor's title in the registry; thus, a buyer who fails to do so takes all the risks. Because the petitioners registered their deeds of sale (tracing back to the original owner through Emiliana Abad), their rights must prevail over the unregistered claims of the respondents.
Main Doctrine
The doctrine of res judicata bars re-litigation of issues already determined by a final judgment. Furthermore, acquisitive prescription requires possession in concept of owner, which is interrupted by judicial summons and cannot be tacked if the predecessor lost in litigation. Registration of title under the Property Registration Decree is crucial for protection against third parties.