White Plains Association v. Legaspi
REITERATIONFacts
The Antecedents: The core dispute revolves around the widening of Katipunan Road within the White Plains Subdivision in Quezon City. Respondent Quezon City Development and Financing Corporation (QCDFC) was the original owner and developer of the subdivision. During the sale of lots, QCDFC represented that a 38-meter width would be dedicated for Katipunan Avenue. While QCDFC developed 20 meters of this width, an 18-meter portion remained undeveloped. QCDFC later sought to convert this undeveloped portion into a residential lot, a move that was initially granted by a lower court but faced opposition from the White Plains Association, Inc. (petitioner). Procedural History: This case marks the second appearance before the Supreme Court, the first being G.R. No. 55868. In that prior instance, the Court of Appeals initially ruled in favor of the petitioner but later reconsidered its decision. The Supreme Court, in G.R. No. 55868, reversed the Court of Appeals' resolution, ordering the cancellation of titles issued to QCDFC for the undeveloped portion of Road Lot 1 and reinstating the lien, effectively declaring the area as a road lot. This judgment became final in January 1986. Subsequently, in early 1989, the petitioner advocated for the widening of the existing 20-meter Katipunan Road due to traffic congestion. The government allocated funds, and construction began. QCDFC then filed a complaint for injunction with damages against public respondents and the contractors, leading to a temporary restraining order and subsequent preliminary injunction from the Regional Trial Court of Quezon City. The Petition: The petitioner, White Plains Association, Inc., filed this petition for certiorari seeking to annul the orders of the Regional Trial Court dated July 10, 1990, and September 26, 1990, which restored and maintained a writ of preliminary injunction against the widening of Katipunan Road. The petitioner argues that QCDFC's cause of action is barred by res judicata due to the Supreme Court's prior ruling in G.R. No. 55868. The petition contends that the Supreme Court's previous decision definitively established that the undeveloped portion of Road Lot 1 is a road lot, withdrawn from commerce, and intended for public use, thus precluding QCDFC from claiming ownership or demanding compensation for its widening. The petitioner seeks an injunction to allow the continuation of the public road improvement project.
Issue(s)
Whether the respondent judge's orders regarding Road Lot 1 are barred by res judicata due to the prior case, G.R. No. 55868. Whether public respondents may be restrained from proceeding with the widening of Katipunan Road, considering the prior ruling on Road Lot 1's public use and QCDFC's claim for compensation.
Ruling
The petition is GRANTED. The questioned orders of the respondent judge dated July 10, 1990, and September 26, 1990, are reversed and set aside. Respondent QCDFC is directed to execute a deed of donation of the remaining undeveloped portion of Road Lot 1 (approximately 18 meters wide) in favor of the Quezon City government. Otherwise, the Register of Deeds of Quezon City is directed to cancel the registration of said Road Lot 1 in the name of respondent QCDFC under TCT No. 112637 and to issue a new title covering said property in the name of the Quezon City government.
Ratio Decidendi
On the issue of res judicata regarding Road Lot 1: The Court finds that res judicata had set in. G.R. No. 55868 definitively resolved that Road Lot 1 could not be converted into a residential lot and was withdrawn from the commerce of man for public use. The subsequent action by QCDFC, seeking to enjoin the widening based on ownership and just compensation, involves the same parties and subject matter. The cause of action, though framed as an injunction, stems from the same dispute over Road Lot 1's nature, already settled by this Court. Therefore, res judicata bars relitigation of this issue. On the right to widen Katipunan Road and QCDFC's claim for compensation: The Court reiterates that Road Lot 1 is withdrawn from the commerce of man and intended for public use, as established in G.R. No. 55868. The Supreme Court debunked QCDFC's claim for reversion and compensation, emphasizing public policy. Open spaces in subdivisions, including road lots, are mandatory requirements beyond commerce. The fact that Road Lot 1 is still registered in QCDFC's name is a formality and does not negate its public status. The developer's obligation is to donate these road lots. The government's decision to widen the road at its own expense does not entitle QCDFC to compensation, as the property was already dedicated for public use. Public respondents should proceed with the widening project, and QCDFC has no right to demand compensation or obstruct the project.
Main Doctrine
The principle of res judicata bars a subsequent action when the same parties, subject matter, and cause of action are involved, even if the relief sought is different, if the underlying issue has been definitively resolved by a prior Supreme Court decision. Subdivision road lots, once declared withdrawn from the commerce of man for public use, cannot be reverted to private ownership or be subject to claims for compensation by the developer.