Quezon Province v. Marte
REITERATIONFacts
The Antecedents: Private respondent Green Square Properties Corporation (Green Square) allegedly acquired rights over a tract of land (50,497 hectares) from the estate of Don Mariano San Pedro y Esteban via a deed of sale dated August 14, 1996. This land was covered by Tax Declaration No. 09-019-0094 and purportedly part of the land under Titulo de Propriedad No. 4136 dated April 29, 1894. The sale was confirmed by the Regional Trial Court of Bulacan in Intestate Estate Proceeding No. 312-B, leading to the transfer of the tax declaration to Green Square. Procedural History: In G.R. No. 106496, the Supreme Court, in a decision dated December 18, 1996, declared Titulo de Propriedad No. 4136 NULL AND VOID, excluded lands covered by it from Don Mariano's estate, closed the intestate proceedings, and prohibited any exercise of possession or disposition of the estate covered by the titulo. Subsequently, in July 1998, Green Square's tender of payment for real estate taxes on the subject land was refused by the Municipal Treasurer of General Nakar, Quezon. Green Square filed a complaint for quieting of title and mandamus, alleging that this refusal cast doubt on its rights and praying to compel acceptance of the payment. Petitioners (Quezon Province and the Municipal Treasurer) filed a motion to dismiss, citing res judicata. The Regional Trial Court (RTC) denied the motion to dismiss on March 17, 1999, holding that Green Square had legal and equitable title, possession for over thirty years (tacked to its predecessor), and that the present controversy was not about ownership but about the acceptance of tax payments, thus not barred by prior judgment. The RTC's motion for reconsideration was also denied. The Petition: Petitioners assail the RTC's resolution and order denying their motion to dismiss, arguing that the respondent judge committed grave abuse of discretion amounting to lack of jurisdiction by disobeying the Supreme Court's decision in G.R. No. 106496, by making the coverage of the land under Titulo de Propriedad No. 4136 an issue, and by ruling that the complaint was not barred by res judicata.
Issue(s)
Whether the respondent judge committed grave abuse of discretion amounting to lack of jurisdiction in disobeying the Supreme Court's decision in G.R. No. 106496. Whether the respondent judge committed grave abuse of discretion by making the coverage of the land under Titulo de Propriedad No. 4136 an issue. Whether the respondent judge committed grave abuse of discretion in ruling that the complaint in Civil Case No. 329-1 was not barred by prior judgment or res judicata.
Ruling
The petition is GRANTED. The resolution dated March 17, 1999, and the order dated June 22, 1999, of the Regional Trial Court of Infanta, Quezon, Branch 65, are REVERSED and SET ASIDE. The Regional Trial Court is ordered to dismiss Civil Case No. 329-1.
Ratio Decidendi
On the issue of the coverage of the land under Titulo de Propriedad No. 4136: The Supreme Court found that the trial court gravely abused its discretion in declaring the coverage of the subject land under Titulo de Propriedad No. 4136 as an issue needing resolution in a full-blown trial. The private respondent, in its complaint, categorically admitted that the land it purchased was covered by Titulo de Propriedad No. 4136. This fact was not controverted by the petitioners. Therefore, the trial court's act of making this undisputed fact an issue was devoid of support in the record and constituted grave abuse of discretion. On the issue of whether Civil Case No. 329-1 is barred by res judicata: The Supreme Court found that the trial court gravely abused its discretion in denying the motion to dismiss and disregarding the prior ruling in G.R. No. 106496. The four elements of res judicata were examined: final judgment, jurisdiction, judgment on the merits, and identity of parties, subject matter, and causes of action. While the first three were not disputed, the private respondent claimed no identity of causes of action. However, the Court held that the ultimate test for identity of causes of action is whether the same evidence would support both the former and present claims. In this case, the validity of Titulo de Propriedad No. 4136 remained the core issue. The Court noted that Green Square's claim, despite assertions of 30-year adverse possession, was fundamentally based on the deed of sale referencing Titulo de Propriedad No. 4136, and the estate itself had consistently relied on this Spanish title. The prior Supreme Court decision in G.R. No. 106496 had already declared Titulo de Propriedad No. 4136 null and void. Therefore, the present claim, resting on the same void title, was barred by res judicata. A party cannot evade res judicata by merely changing the form of the action or the mode of presenting the case. On the issue of whether the respondent judge committed grave abuse of discretion amounting to lack of jurisdiction in disobeying the Supreme Court's decision in G.R. No. 106496: The Supreme Court's ruling on res judicata effectively addresses the issue of the respondent judge disobeying the Supreme Court's decision in G.R. No. 106496, as the prior ruling declared Titulo de Propriedad No. 4136 null and void, and the present claim rests on the same void title. Therefore, the judge's actions constituted grave abuse of discretion.
Main Doctrine
A party cannot evade the application of res judicata by simply varying the form of the action or by adopting a different mode of presenting its case. The validity of Titulo de Propriedad No. 4136, having been declared null and void in a prior Supreme Court decision, bars a subsequent claim based on said title, even if framed as an action for quieting of title and mandamus.