Swan v. Lladones
REITERATIONFacts
The Antecedents: Petitioners Swan claimed ownership over a People's Homesite and Housing Corporation (PHHC) lot (Block 5, Lot 21) since 1959. Private respondents Lladones occupied an adjacent lot (Block 5, Lot 22) since 1961. The Lladoneses filed an application for the disputed lot in 1977 and obtained TCT No. 286437 in 1982. The Swans filed Civil Case Q-90-5183 for annulment and cancellation of title. Procedural History: The Court of Appeals dismissed the Swans' complaint, ruling that the proper remedy should have been a special civil action for certiorari alleging grave abuse of discretion by the National Housing Authority (NHA), citing Raymundo vs. PHHC. Meanwhile, the Lladoneses had filed several cases, including ejectment cases against Maria Swan (mother of petitioners) and Raymunda Ala, which resulted in decisions in favor of the Lladoneses. After the Swans were ejected and reentered the premises, the Lladoneses filed a forcible entry case (Civil Case No. 37-2571), which was decided in their favor. The Swans appealed this decision, and the RTC granted execution pending appeal. The sheriff issued a notice to vacate. The Petition: The Swans filed a petition (G.R. No. 97319) seeking to set aside the Court of Appeals' decision dismissing their annulment complaint and another petition (G.R. No. 104554) to restrain the RTC from proceeding with the execution pending appeal.
Issue(s)
Whether the Court of Appeals erred in dismissing the Swans' complaint for annulment of title on the ground that the proper remedy was a special civil action for certiorari. Whether the Swans' action for annulment of title is barred by res judicata.
Ruling
The Court set aside the assailed decision of the Court of Appeals in G.R. No. 97319. However, it ordered the dismissal of Civil Case No. Q-90-5183 on the ground of res judicata. The prayer for a temporary restraining order in G.R. No. 104554 was denied.
Ratio Decidendi
On the propriety of the remedy: The petitioners are correct that their action for annulment of title falls within the original jurisdiction of the Regional Trial Courts. The ruling in Raymundo vs. PHHC pertains to actions to annul NHA awards of sale, not annulment of title itself. The proper procedure for annulling an NHA award typically involves an appeal to the Office of the President, followed by a Rule 65 action if there is an allegation of grave abuse of discretion or lack of jurisdiction. Therefore, the Court of Appeals erred in dismissing the annulment complaint solely on the procedural ground that it should have been a certiorari action. On res judicata: Despite the procedural correctness of filing an annulment of title case, the Court found that Civil Case No. Q-90-5183 must be dismissed due to res judicata. The requisites for res judicata are present: identity of parties (or those in privity), identity of subject matter, and identity of causes of action. The 1977 annulment case, which was affirmed by the Court of Appeals in CA-G.R. SP No. 14209-R, involved the same parties and the same disputed lot. The underlying relief sought in both the 1977 and 1990 cases was the annulment of the NHA's award of the disputed lot to the Spouses Lladones. The inconsistency test confirms the identity of causes of action; granting the 1990 petition would contradict the prior judgment that the question of ownership/possession had already been threshed out in favor of the Lladoneses. Therefore, the prior judgment bars the present action.
Main Doctrine
A subsequent action for annulment of title may be dismissed on the ground of res judicata if it involves the same parties, subject matter, and cause of action as a prior annulment case that was decided on the merits, even if the subsequent action is formulated differently.