Veloso, Jr. v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondents filed a complaint for quieting of title with damages against petitioners concerning Lot No. 8422-F, covered by TCT No. 22393 in the name of Crispina Peñalosa Miraflor, deceased mother of respondents. Procedural History: The Regional Trial Court (RTC) rendered judgment finding TCT No. T-22393 authentic and valid, declaring respondents as absolute co-owners, ordering petitioners to deliver possession of Lot No. 8422-F, and awarding attorney's fees and litigation expenses. The Court of Appeals (CA) affirmed the RTC decision. Petitioners elevated the case to the Supreme Court, which denied their petition for review on the ground that the issues were essentially factual and there was no reversible error. Subsequently, petitioners filed a petition for annulment of the RTC decision before the CA, which was again denied. The CA found that the controversy had already been settled by the Supreme Court and that the contention regarding the RTC's lack of power to amend a decision of a co-equal court should have been raised earlier. The Petition: Petitioners seek a reversal of the CA decision dismissing their petition to annul the RTC judgment, claiming the RTC decision was flawed because the issues were already resolved in prior cases involving the same parties and subject matter, and that a trial court cannot countermand a decision of a co-equal court.
Issue(s)
Whether respondent Court of Appeals erred in refusing to declare the decision of the trial court void for having been rendered allegedly in violation of the doctrines of res judicata and the law of the case. Whether the rulings in Civil Cases Nos. R-205 and B-122 constitute res judicata or the law of the case to Civil Case No. B-1043.
Ruling
The petition is DENIED. The decision of respondent Court of Appeals dated 29 July 1994 is AFFIRMED.
Ratio Decidendi
On the issue of whether respondent Court of Appeals erred in refusing to declare the decision of the trial court void for having been rendered allegedly in violation of the doctrines of res judicata and the law of the case: The Supreme Court held that petitioners, under the guise of a petition for annulment of judgment, were in effect seeking a second cycle of review on a subject matter that had already been fully and fairly adjudicated. This is not permissible. The Court emphasized that the doctrines of res judicata and the law of the case, which petitioners invoked, actually barred their present proceeding. The Court clarified that material facts or questions in issue in a former action, once admitted or judicially determined, are conclusively settled by the judgment therein and may not be relitigated in a subsequent action between the same parties or their privies, regardless of the form of the subsequent action or the cause of action. Furthermore, whatever is once irrevocably established as the controlling legal principle or decision continues to be the law of the case between the same parties in the same case, so long as the facts on which such decision was predicated remain the same. The Court found no reversible error in the CA's denial of the annulment petition, as the matter had already been settled by prior Supreme Court decisions. On the issue of whether the rulings in Civil Cases Nos. R-205 and B-122 constitute res judicata or the law of the case to Civil Case No. B-1043: The Court found no merit in petitioners' contention that prior decisions in Civil Cases Nos. R-205 and B-122 established res judicata or the law of the case that would nullify the decision in Civil Case No. B-1043. Instead, the Court held that it was the ruling in Civil Case No. B-1043, which had been affirmed by the CA and the Supreme Court, that now served as a bar to the present proceeding under the same doctrines. The Court meticulously examined the facts and findings in the prior cases, noting that while they touched upon Lot No. 8422 and its ownership, the specific issue in Civil Case No. B-1043, concerning the authenticity and validity of TCT No. 22393 and the co-ownership of respondents over Lot No. 8422-F, was distinct and had been definitively resolved. The trial court in Civil Case No. B-1043 had provided detailed reasoning, based on the totality of evidence, to distinguish the subject matter of the 1948 deed of sale from Crispina P. Miraflor's share in Lot 8422-F, thereby negating the petitioners' claim that the prior decisions conclusively settled the ownership of Lot No. 8422-F in their favor.
Main Doctrine
A petition for annulment of judgment cannot be used to seek a second cycle of review on a matter already fully and fairly adjudicated, especially when the issues raised were already passed upon by the Supreme Court.