Reyes v. Solemar Development
REITERATIONFacts
The Antecedents: This case concerns a parcel of land, Lot 1 of subdivision plan Psd-18002, located in Barangay San Dionisio, Parañaque City. The petitioners, Spouses Arsenio and Nieves Reyes, claim to be the registered owners of this land, holding Transfer Certificate of Title (TCT) No. 31798 (40312). The dispute arose when the Reyeses alleged that respondents, Solemar Development Corporation (Solemar) and its president Renato Tanseco, along with police officers, unlawfully entered their property in December 1991 and January 1992, demolished their fence, and attempted to eject them. Solemar, however, asserted ownership of the property and questioned the authenticity of the Reyeses' title. Procedural History: The litigation involves two consolidated petitions. In G.R. No. 129247, the Reyeses filed a complaint for damages and injunction against Solemar and Tanseco in the RTC, alleging forcible entry. The RTC admitted their amended complaint, but the Court of Appeals reversed this, finding the case to be one of forcible entry within the Municipal Trial Court's jurisdiction. This Court affirmed the Court of Appeals' decision. Subsequently, the RTC denied Solemar's motion to dismiss, asserting its jurisdiction over damages and ownership claims. The Court of Appeals again ruled in favor of Solemar, ordering the RTC to dismiss the case for lack of jurisdiction, a decision this Court ultimately upheld. In G.R. No. 136270, the Republic of the Philippines filed a complaint to nullify the Reyeses' title, citing its doubtful authenticity. The RTC ruled in favor of Solemar in a separate quieting of title case, declaring the Reyeses' title spurious. The Reyeses' appeal and subsequent motions were denied, and their title was cancelled. The Republic's motion to withdraw its nullification complaint was initially denied by the RTC, but the Court of Appeals granted it, leading to the Reyeses' petition to this Court. The Petition: In G.R. No. 129247, the petitioners, Spouses Arsenio and Nieves Reyes, filed a Petition for Review on Certiorari, seeking to overturn the Court of Appeals' decision that their complaint was for forcible entry, thus falling under the Municipal Trial Court's jurisdiction. They argued that the RTC had jurisdiction due to the claims for damages and the issue of ownership. In G.R. No. 136270, the Reyeses filed a Petition for Review on Certiorari, seeking to reverse this Court's resolution denying their motion for reconsideration. They contended that the dismissal of the Republic's complaint would prevent them from recovering damages from the Assurance Fund. This Court denied both petitions, citing res judicata and the stability of judgments, and affirmed the Court of Appeals' rulings that the initial complaint was for forcible entry and that the issues of title and ownership had been settled in prior cases.
Issue(s)
Whether the RTC has jurisdiction over petitioners' complaint, which was captioned as one for damages and preliminary injunction but alleged acts constituting forcible entry. Whether the principle of res judicata bars the Republic's complaint for declaration of nullity of TCT No. 31798 (40312) and petitioners' counterclaim, given the prior final and executory decision in the quieting of title case. Whether the dismissal of the Republic's complaint and petitioners' counterclaim in Civil Case No. 92-2135 is proper, and whether petitioners can pursue their claim against the Assurance Fund.
Ruling
The Supreme Court denied the petition in G.R. No. 129247 and denied the motion for reconsideration in G.R. No. 136270. The Court affirmed the Court of Appeals' order for the RTC to dismiss the complaint in Civil Case No. 92-109 for lack of jurisdiction, and upheld the denial of petitioners' motion for reconsideration in G.R. No. 136270 on the grounds of res judicata and stability of judgments.
Ratio Decidendi
On the jurisdiction of the RTC in G.R. No. 129247: The Court held that the Court of Appeals did not err in ordering the RTC to dismiss petitioners' complaint. Jurisdiction over the subject matter is determined by the allegations in the complaint, irrespective of the plaintiff's entitlement to recovery. The allegations in paragraphs 4, 10, and 15 of the complaint, coupled with the filing date within one year of the alleged forcible entry, indicated that the complaint was for forcible entry, which falls under the exclusive jurisdiction of the Municipal Trial Court (MTC). While captioned as a complaint for damages with application for TRO and preliminary injunction, the core of the allegations asserted petitioners' right to peaceful possession, which is the subject of an ejectment suit. The Court reiterated that all ejectment cases are within the jurisdiction of the MTC. Therefore, the RTC correctly dismissed the case for lack of jurisdiction. On res judicata and stability of judgments in G.R. No. 136270: The Court found the dismissal of the Republic's complaint and petitioners' counterclaim to be proper based on the principle of res judicata and the stability of judgments. The issue of the doubtful authenticity of TCT No. (31798) 40312 had already been passed upon and decided with finality in Civil Case No. 93-1566, where Solemar's titles were declared valid and petitioners' title was declared spurious. This decision became final and executory after it was sustained on appeal and the petition for review was adversely resolved by the Supreme Court. The Court rejected the Solicitor General's argument that the Republic was not bound by the decision in Civil Case No. 93-1566, stating that substantial identity of parties is sufficient, and the Republic, through the Register of Deeds, was involved in the quieting of title case. Allowing the remand of the case would violate the principle of stability of judgments. The Court also found the dismissal of petitioners' counterclaim proper, as it was ancillary to the main controversy, and the ruling on the spurious title necessarily dismissed their claim that the title be declared genuine. Regarding their claim against the Assurance Fund, the Court agreed with the Court of Appeals that such action should be filed separately against the proper parties (Register of Deeds and National Treasurer) and with sufficient allegations of fraud or negligence, which were lacking in the counterclaim.
Main Doctrine
The Court of Appeals did not err in ordering the RTC to dismiss the complaint for damages and preliminary injunction, finding it to be a case of forcible entry falling under the exclusive jurisdiction of the Municipal Trial Court, as jurisdiction is determined by the allegations in the complaint. Furthermore, the principle of res judicata bars the relitigation of issues already passed upon and decided by final and executory judgments, including the validity of land titles.