Jesus v. Manzano
REITERATIONFacts
The Antecedents: Plaintiff Jacinto de Jesus y Ladao alleged ownership of a parcel of rice land in Bacao, San Marcelino, Zambales, founded on a possessory information title judicially approved on July 16, 1895. He claimed to have possessed the land as owner until January 1912, when he was deprived of possession pursuant to a judgment in a forcible entry and detainer case (Case No. 157) filed by the defendant, Luis Manzano. The land was then delivered to Manzano, who allegedly held it to the prejudice of De Jesus. Procedural History: The Court of First Instance of Zambales ordered the delivery and return of the land to the plaintiff and payment of costs. The defendant appealed this judgment. The Petition: The plaintiff prayed for an award of ownership and possession, an order for the defendant to cease disturbing his possession, payment of damages amounting to P90, and costs. The defendant, in his answer, denied the allegations and asserted his ownership based on a fifteen-year possession, claiming the land was in Tabuyeyeng, not Bacao. He also alleged that De Jesus forcibly reoccupied the land in July 1912, causing him damages of P300.
Issue(s)
Whether the judgment in the prior forcible entry and detainer case (Case No. 157) operates as res judicata in the present action for recovery of possession. Whether the plaintiff has established a better right to the ownership and possession of the disputed land.
Ruling
The judgment of the Court of First Instance is affirmed. The defendant is ordered to return the parcel of land to the plaintiff, with costs against the appellant.
Ratio Decidendi
On the issue of res judicata: The Court held that the judgment rendered in the previous action for forcible entry and detainer between the same parties cannot be set up as res judicata in the present action to recover possession. Section 87 of the Code of Civil Procedure explicitly provides that a judgment in an unlawful entry and detainer suit is not conclusive proof in another action between the same parties arising out of a different cause of action, nor does it bar an action in the Court of First Instance respecting title to the land. Therefore, the prior judgment does not support the defendant's exception of res judicata. On the issue of ownership and possession: The Court found that the plaintiff's possessory information title, judicially approved on July 16, 1895, and recorded in the property registry on February 16, 1896, established his right. The proceedings complied with the Mortgage Law, and the defendant, as an adjoining landowner, was duly notified and acquiesced to the application, indicating his knowledge and lack of objection to the plaintiff's possession as owner. The evidence, including the plaintiff's testimony and sketch Exhibit A, corroborated the plaintiff's claim to the land in Bacao, which was distinct from the land the defendant claimed in Tabuyeyeng. The defendant's contradictory statements regarding his period of possession in the prior case and the present one cast doubt on his veracity. Furthermore, under the Mortgage Law and the Code of Civil Procedure, the plaintiff's entry of possession had been converted into a record of ownership, as sixteen years had elapsed from the date of entry, and ten years are sufficient under the Code of Civil Procedure to convert such an entry into a record of ownership.
Main Doctrine
A judgment in a forcible entry and detainer case does not bar a subsequent action between the same parties concerning the title to the land, as the former is not conclusive proof of ownership and does not preclude an action in the Court of First Instance respecting title.