Serrano v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns two parcels of riceland in Bo. Wawa, Kay Bagsak, Siniloan, Laguna. The petitioners, spouses Ricardo Serrano and Fidela Castalone, claimed ownership based on a deed of sale. The respondents, Miguel Advento, Damian Canawin, and Fidel Adofina, denied the petitioners' claim, asserting they were merely tenants of the property's actual owners, Isabel Advento and others. 2. Procedural History: Two civil actions, Civil Case No. S-185 and Civil Case No. S-251, were filed concerning the same property. In Civil Case No. S-185, Isabel Advento, et al. sued Ricardo Serrano, et al. (herein petitioners) for quieting of title and recovery of possession. The Regional Trial Court (RTC) of Laguna ruled in favor of Isabel Advento, et al., declaring them owners. The petitioners' appeal in this case was dismissed for being filed out of time, rendering the judgment final. Subsequently, in Civil Case No. S-251, where the petitioners sued the respondents for quieting of title, the RTC dismissed their complaint, deeming it moot and academic due to the prior judgment in Civil Case No. S-185. The Court of Appeals affirmed the RTC's dismissal, and a motion for reconsideration was denied. 3. The Petition: This case is a petition for review on certiorari filed under Rule 45 of the Rules of Court, seeking to reverse the Court of Appeals' decision. The petitioners argue that the Court of Appeals erred in affirming the dismissal of their complaint in Civil Case No. S-251. They contend that the prior judgment in Civil Case No. S-185, which declared ownership in favor of Isabel Advento, et al., should not have rendered their own action moot and academic, and that the issue of ownership was improperly decided against them.
Issue(s)
Whether the Court of Appeals acted contrary to law in affirming the dismissal of the complaint in Civil Case No. S-251. Whether the petitioners have legal or equitable title to the property in dispute sufficient to maintain an action to quiet title.
Ruling
The petition is denied. The decision of the Court of Appeals dated November 27, 1986, is affirmed.
Ratio Decidendi
On the issue of whether the Court of Appeals acted contrary to law in affirming the dismissal of the complaint in Civil Case No. S-251: The Supreme Court held that the Court of Appeals did not act contrary to law. To maintain an action to quiet title, the plaintiff must possess legal or equitable title to, or interest in, the property in dispute, as provided by Article 477 of the Civil Code. In this case, the RTC in Civil Case No. S-185 had already ruled in favor of Isabel Advento, et al., declaring them the owners of the property against the herein petitioners, who were defendants in that case. This judgment became final and executory, making the ownership of Isabel Advento, et al. incontestable and binding upon the petitioners. The subject parcels of land in Civil Case No. S-251 were the very same parcels of land adjudged in Civil Case No. S-185 as belonging to Isabel Advento, et al. Therefore, the petitioners were bound by the judgment in Civil Case No. S-185. On the issue of whether the petitioners have legal or equitable title to the property in dispute sufficient to maintain an action to quiet title: The Supreme Court affirmed the lower courts' findings that the petitioners lacked the necessary title. The prior judgment in Civil Case No. S-185, which declared Isabel Advento, et al. as the owners of the disputed land, was binding on the petitioners. This judgment rendered the petitioners' claim of ownership and their subsequent action to quiet title in Civil Case No. S-251 moot and academic. Furthermore, the policy of the law is to avoid multiplicity of suits, and an issue already resolved in one case cannot be relitigated in a subsequent case, even if based on a different cause of action, if it involves the same issue. The issue of ownership of the property in question had been resolved with finality in Civil Case No. S-185 against the petitioners. The respondents, being mere lessees of Isabel Advento, et al., had no claim of ownership themselves and admitted that the land belonged to Isabel Advento, et al. Thus, the petitioners had no cause of action against the respondents.
Main Doctrine
A complaint for quieting of title and recovery of possession becomes moot and academic when a prior, final, and executory judgment in another case involving the same property has already declared another party as the owner, and the plaintiffs in the new action are bound by the prior judgment.