Catholic Vicar Apostolic of the Mountain Province v. Court of Appeals
REVERSALFacts
The Antecedents: Petitioner Catholic Vicar Apostolic of the Mountain Province (hereinafter referred to as petitioner) and private respondents, Heirs of Egmidio Octaviano and Heirs of Juan Valdez, were involved in a land registration case (CA-G.R. No. 38830-R) where both parties sought confirmation of their alleged imperfect titles to Lots 2 and 3 under Section 49(b) of the Public Land Act. The Court of Appeals, in its decision dated May 4, 1977, found petitioner not entitled to confirmation of its imperfect title to Lots 2 and 3. Separate motions for reconsideration by the private respondents, seeking registration of these lots in their names, were denied by the Court of Appeals on August 12, 1977. This effectively meant that neither petitioner nor private respondents were entitled to confirmation of imperfect title over these lots, and they remained part of the public lands. Procedural History: Petitioner filed a petition for review of the Court of Appeals' decision in CA-G.R. No. 38830-R with this Court (G.R. No. L-46832), and the heirs of Juan Valdez also filed a petition for review (G.R. No. L-46872). Both petitions were denied by this Court in a minute resolution dated January 13, 1978, for lack of merit. The present case involves a motion for reconsideration and a supplemental motion for reconsideration filed by petitioner regarding a decision of this Court dated September 21, 1988. The Petition: Petitioner argues that the findings of fact of the Court of Appeals in CA-G.R. No. 38830-R were contrary to law, the findings of the trial court, other findings of the Court of Appeals, admissions of the parties, and based on a misapprehension of historical and ecclesiastical facts. The core issue revolves around who is entitled to the possession of Lots 2 and 3, considering the prior rulings.
Issue(s)
Whether the findings of fact in the Court of Appeals' decision in CA-G.R. No. 38830-R, which had become final and executory after denial of petitions for review, can be re-examined. Whether the private respondents are entitled to the possession of Lots 2 and 3, and the nature of the actions filed. Whether Lots 2 and 3 are part of the public domain.
Ruling
The motion for reconsideration is GRANTED. The decision of this Court dated September 21, 1988, is set aside, and another judgment is rendered reversing and setting aside the decision of the appellate court in CA-G.R. Nos. 05148-49 dated August 31, 1987, and dismissing the complaints for recovery of possession, without pronouncement as to costs.
Ratio Decidendi
On the finality of prior rulings: The Court held that the findings of fact in the Court of Appeals' decision in CA-G.R. No. 38830-R, which was elevated to this Court through petitions for review (G.R. Nos. L-46832 and L-46872) and subsequently denied for lack of merit, have long become final and executory. Therefore, the principle of res judicata applies, making those factual findings conclusive and not subject to review in the present proceedings. The petitioner should have raised its objections to the factual findings in the prior petitions for review. On the entitlement to possession and nature of actions: The Court found that the trial court and the Court of Appeals erred in ordering the petitioner to return and surrender possession of Lots 2 and 3 to the private respondents. The factual findings in CA-G.R. No. 38830-R indicated that the petitioner possessed the property as a borrower in commodatum since 1906, but repudiated the trust in 1951 by declaring the property for tax purposes under its name. By 1962, when the application for registration was filed, the petitioner had been in adverse possession for at least 11 years. Article 555(4) of the Civil Code states that the real right of possession is not lost until after the lapse of ten years of possession by another. Since the petitioner's adverse possession exceeded ten years, the private respondents' action for recovery of possession (accion publiciana) must fail. The Court clarified that the actions instituted in the Regional Trial Court by the private respondents were accion publiciana (actions for recovery of possession) and not accion reivindicatoria (actions for recovery of ownership). This distinction is crucial because the success of an accion publiciana depends on the plaintiff's better right of possession, which in this case was extinguished by the petitioner's prolonged adverse possession. On the nature of Lots 2 and 3: Based on the final and executory decision in CA-G.R. No. 38830-R, the Court concluded that neither the petitioner nor the private respondents were entitled to the confirmation of imperfect title over Lots 2 and 3. Consequently, these lots remained part of the public lands, and their disposition is governed by the provisions of the Public Land Act, as amended. The appellate court's ruling that these lots are public lands is now res judicata. Given that Lots 2 and 3 are public lands and the private respondents' right to possession was lost due to the petitioner's adverse possession for over ten years, the complaints for recovery of possession filed by the private respondents were dismissed. The Court emphasized that the private respondents could not claim ownership of the lots as they remained part of the public domain.
Main Doctrine
The findings of fact in a prior final and executory judgment, particularly on the issue of who is entitled to confirmation of imperfect title over certain lots, are considered res judicata and cannot be reviewed anew in subsequent proceedings. If neither party is found entitled to confirmation of imperfect title, the lots remain part of the public domain, and their disposition is governed by the Public Land Act. Actions for recovery of possession (accion publiciana) must fail if the plaintiff's real right of possession has been lost due to the adverse possession of another for the statutory period.