Toledo-Banaga v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Banaga sought to redeem property previously foreclosed and sold at public auction to private respondent Damalerio. Certificates of Title were issued to Damalerio. Banaga annotated a notice of lis pendens. The Court of Appeals (CA) reversed the trial court, allowing Banaga to redeem within a period. This decision became final. Procedural History: Banaga attempted to redeem by depositing the redemption amount, financed by co-petitioner Tan. Damalerio opposed, arguing it was beyond the period. The trial court upheld the redemption and ordered the cancellation of Damalerio's titles and issuance of new ones to Banaga. Damalerio filed a petition for certiorari with the CA, which issued a temporary restraining order (TRO). Meanwhile, Banaga sold the property to Tan. Tan subdivided the property and obtained new titles in her name, still carrying the lis pendens annotations. The CA set aside the trial court's orders, declared Damalerio the absolute owner, and ordered the cancellation of titles. This decision became final. Upon motion, the trial court issued a writ of execution ordering the Register of Deeds to reinstate Damalerio's titles. The Register of Deeds refused, citing the need to surrender Tan's titles. The trial court denied Damalerio's motion to cite the Register of Deeds in contempt and ruled that Damalerio's remedy was a consulta. Damalerio again elevated the case to the CA, which set aside the trial court's orders, declared Tan's titles null and void, and ordered the issuance of new titles to Damalerio, along with a writ of possession. The Petition: Petitioners (Banaga and Tan) filed the instant petition for certiorari and mandamus seeking to set aside the CA's decision, arguing that Tan was a buyer in good faith and that Damalerio's remedy was by consulta, not contempt.
Issue(s)
Whether the principle of res judicata bars the re-litigation of the ownership of the subject property. Whether petitioner Tan is a buyer in good faith. Whether the remedy of private respondent Damalerio to secure titles in his name is by consulta to the Land Registration Commissioner or through other legal means. Whether the execution of a final and executory decision, including the issuance of titles and possession, can be compelled by mandamus despite the non-surrender of duplicate Certificates of Title.
Ruling
The petition is DENIED. The assailed decision of the Court of Appeals is AFFIRMED in toto. No further proceedings will be entertained in this case.
Ratio Decidendi
On the issue of res judicata: The Court held that the principle of res judicata clearly applies, barring petitioners from re-litigating the ownership of the subject property. The prior CA decision, affirmed by the Supreme Court, had already declared private respondent Damalerio as the absolute owner. All elements of res judicata were present: a final and executory judgment, jurisdiction of the court, judgment on the merits, and identity of parties, subject matter, and cause of action. To allow re-litigation would defeat the purpose of courts as final arbiters and would lead to endless litigation. The Court emphasized that a final and executory judgment cannot be disturbed, regardless of any perceived error. On the issue of petitioner Tan being a buyer in good faith: The Court found that petitioner Tan was a buyer in bad faith. She was aware of the lis pendens annotations and the pending litigation concerning the property. Furthermore, the deed of sale itself mentioned that the certificates of title were not in the seller's (Banaga's) name but in Damalerio's name. Tan even had the property subdivided not in her name but in Damalerio's name. Her knowledge of the defects in Banaga's title, coupled with the lis pendens notices, bound her to the outcome of the litigation. As a transferee pendente lite, she stepped into the shoes of her predecessor and was bound by the judgment against Banaga. Her subsequent issuance of titles did not protect her from the effects of the prior decision. On the remedy for securing titles: The Court rejected the argument that Damalerio's sole remedy was a consulta. It stated that the enforcement of a final and executory decision, including the issuance of titles and possession, is a ministerial duty of the courts and the Register of Deeds. To require a separate action for cancellation of titles or to compel the surrender of duplicate titles would render the execution process nugatory and allow parties to trifle with court orders. The CA correctly declared Tan's titles null and void and ordered the issuance of new titles to Damalerio. On the enforceability of the judgment by mandamus: The Court affirmed that the enforcement of a final and executory judgment is a ministerial function, and a writ of mandamus lies to compel its performance. The argument that execution cannot be had due to the non-surrender of duplicate titles was deemed preposterous and without merit. The surrender of the duplicate title is implied from the executory decision, and it is the ministerial duty of the Register of Deeds to comply with the court's order to issue a title to the rightful owner. The CA's order for a writ of possession was also affirmed, as the right to possession is a necessary incident of ownership, and the defeated parties had no right to retain possession independently of their rejected claim of ownership.
Main Doctrine
The principle of res judicata bars the re-litigation of issues already settled by a final and executory judgment. Furthermore, a buyer in bad faith, even if subsequently issued a title, is bound by the outcome of prior litigation involving the property, and cannot acquire rights superior to their predecessor-in-interest. Enforcement of a final and executory judgment, including the issuance of titles and possession, is a ministerial duty.