Calalang v. Register of Deeds of Quezon City
REITERATIONFacts
1. The Antecedents: The core dispute revolves around Lot 671 of the Piedad Estate in Quezon City. Petitioners in both cases claim ownership of portions of Lot 671-A, asserting they purchased their respective parcels from Amando Clemente in the 1950s, who held Transfer Certificate of Title (TCT) No. 16212 for a significant portion of the land. Respondent Iglesia ni Kristo (INK) claims ownership of the larger Lot 671, having purchased it from Lucia de la Cruz in 1975. The validity of Lucia de la Cruz's title to Lot 671, and consequently INK's title derived from her, has been the subject of prior litigation. 2. Procedural History: The underlying controversy traces back to the case of dela Cruz v. dela Cruz (130 SCRA 666), where the Supreme Court affirmed the Court of Appeals' decision validating Lucia de la Cruz's sale of Lot 671 to INK. This Supreme Court decision led to the present consolidated petitions. In G.R. No. 76265, Virginia Calalang's petition for certiorari and prohibition against the Register of Deeds and the Administrator of the National Land Titles and Deeds Registration Administration (NLTDRA) stemmed from the denial of her motion to intervene in a consulta case concerning the registrability of conflicting titles. In G.R. No. 83280, petitioners, including Augusto M. de Leon, filed an injunction suit with damages against INK due to INK's actions in fencing and constructing on their claimed portions of Lot 671-A. This case was dismissed by the Regional Trial Court (RTC), and the Court of Appeals initially set aside the dismissal to allow for a hearing on the preliminary injunction, but later denied a motion to dismiss the complaint. The RTC's subsequent dismissal of the injunction case was also challenged. 3. The Petition: Both petitions, consolidated as G.R. Nos. 76265 and 83280, are petitions for review on certiorari seeking to overturn decisions that upheld the validity of Lucia de la Cruz's title and, by extension, INK's title to Lot 671. Petitioners argue that the Supreme Court's ruling in dela Cruz v. dela Cruz should not apply to them as they were not parties to that case and acquired their titles from Amando Clemente, not from any of the parties in the prior litigation. They contend that their titles, derived from Clemente, predate or are otherwise superior to the title claimed by Lucia de la Cruz and INK. The core of their argument is that their right to their properties has not been extinguished by the prior Supreme Court decision and that they are being deprived of their property without due process. They seek to have their titles recognized and the claims of INK and Lucia de la Cruz invalidated.
Issue(s)
Whether the Supreme Court's decision in dela Cruz v. dela Cruz operates as res judicata or conclusiveness of judgment against the petitioners who were not parties to the said case. Whether the petitioners, claiming title from Amando Clemente, can assert a better right than that of Lucia de la Cruz and subsequently Iglesia ni Cristo (INK), whose titles were upheld in the dela Cruz case. Whether the titles derived from Amando Clemente, which originated from Eugenia de la Paz and Dorotea de la Cruz, are valid despite the prior adjudication of ownership in favor of Lucia de la Cruz over Lot 671. Whether the petitioners are entitled to relief despite the finality of the dela Cruz ruling and the principles of the Torrens system, considering the nature of the proceedings and the prohibition against collateral attacks on certificates of title, and whether applying the dela Cruz ruling deprives them of due process.
Ruling
The petitions are DISMISSED for lack of merit. The Supreme Court's decision in dela Cruz v. dela Cruz is binding on the present petitioners under the principle of res judicata and conclusiveness of judgment. The titles derived from Amando Clemente are declared null and void to prevent the proliferation of derivative titles that are null and void. The legality and validity of INK's title over Lot 671 have been settled with finality.
Ratio Decidendi
On the applicability of res judicata and conclusiveness of judgment: The Court held that the decision in dela Cruz v. dela Cruz is binding on the present petitioners. The principle of res judicata, or conclusiveness of judgment, dictates that when a right or fact has been judicially tried and determined by a court of competent jurisdiction, and remains unreversed, it is conclusive upon the parties and those in privity with them. Although the petitioners were not direct parties to the dela Cruz case, they are considered in privity with the parties whose rights they claim to have derived from. The Court emphasized that petitioners could acquire no more rights than the source of their titles, and since their source's predecessors-in-interest (Eugenia de la Paz and Dorotea de la Cruz) lost their rights by virtue of the sale to Lucia de la Cruz, the petitioners cannot assert a superior claim. The factual inquiry into the history of Lot 671 has already been laid to rest by the prior decision. On the validity of titles derived from Amando Clemente: The Court found that Amando Clemente's TCT No. 16212 emanated from TCT No. 40355, which was in the names of Eugenia de la Paz and Dorotea de la Cruz. However, these individuals had already sold Lot 671 to Lucia de la Cruz in 1943, and this sale was registered. The dela Cruz case affirmed the validity of Lucia de la Cruz's title. Therefore, any title derived from Eugenia de la Paz and Dorotea de la Cruz after their sale to Lucia de la Cruz, including that of Amando Clemente, is considered void. The principle of prior est tempore, prior est in jura (he who is first in time is preferred in right) applies, and Lucia de la Cruz's registered sale in 1943 predates Amando Clemente's alleged title in 1951. The Court noted that Amando Clemente's possession of a certificate of title does not necessarily make him the true owner, nor can he transmit rights he does not possess. On the Torrens System and indefeasibility of titles: The Court reiterated that the Torrens system aims to ensure stability and quiet title. The registration of the sale of Lot 671 to Lucia de la Cruz in 1943 constituted constructive notice to the whole world. Her reconstituted title (TCT No. RT-58) was declared valid in the dela Cruz case and became indefeasible and incontrovertible. Similarly, the title issued to INK in 1975, as a purchaser in good faith for value from Lucia de la Cruz, also became indefeasible and incontrovertible one year after its decree. It is too late for the petitioners to question the legality of INK's title at this juncture, as this would defeat the purpose of the Torrens system. On the nature of the proceedings, collateral attack, due process, and finality of judgment: The Court pointed out that the petition in G.R. No. 76265 stemmed from a consulta case, and the arguments raised by the petitioners required adjudication of facts, which the Supreme Court is not a trier of. Furthermore, challenging the validity of a certificate of title through such proceedings constitutes a collateral attack, which is not permissible. A certificate of title can only be altered, modified, or cancelled in a direct proceeding in accordance with law. The Court cited Section 48 of the Property Registration Decree, which expressly prohibits collateral attacks on a certificate of title. The petitioners' contention that the application of the dela Cruz ruling would deprive them of their properties without due process was rejected. The Court found no warrant to reopen the validity of Lucia de la Cruz's reconstitution proceedings. The dela Cruz ruling has long been final and executory, and to reopen it would undermine the stability of legal relations and the integrity of the Torrens system. The Court stressed that it has the final word on what the law is, and a decision of the Highest Tribunal must be respected.
Main Doctrine
A prior Supreme Court decision on the ownership of a parcel of land, which has become final and executory, operates as res judicata and bars the relitigation of the same issue by parties or those in privity with them, even if they were not direct parties to the original case, as they could acquire no more rights than the source of their titles. The Torrens system aims to ensure stability and quiet title, making titles indefeasible and incontrovertible after a certain period.