Abadilla v. Galarosa
REITERATIONFacts
The Antecedents: Respondent Gregorio B. Galarosa (Galarosa) filed a Petition for Reconstitution of Lost Title, Transfer Certificate of Title (TCT) No. 261465, before the RTC, Branch 105. The RTC, through Judge Tadeo, issued an Order directing the Register of Deeds of Quezon City to reconstitute the title, noting compliance with publication and posting requirements, and the presentation of a genuine owner's duplicate copy. However, when Galarosa presented the order to the Register of Deeds, compliance was refused. Subsequently, RTC, Branch 105, through Judge Ulep, denied Galarosa's motion to compel reconstitution, citing the discovery of a spurious signature on the title and findings from the LRA Administrator and NBI that the title was not duly issued to the Registry of Deeds of Quezon City. Galarosa's motion for reconsideration was denied. Procedural History: Three years later, Galarosa filed a Complaint for Recovery of Ownership, Annulment of Title with Damages, seeking to annul TCT No. 60405 in the name of the deceased Rolando N. Abadilla. The Heirs of Rolando N. Abadilla (Abadillas) moved for dismissal, arguing the complaint was barred by prior judgment, citing the RTC Branch 105 orders declaring Galarosa's title spurious. RTC, Branch 84, dismissed Galarosa's complaint, holding it was barred by prior judgment. Galarosa appealed to the Court of Appeals (CA). The Petition: The CA reversed the RTC's dismissal, finding no identity of cause of action between the reconstitution case and the civil action for recovery of ownership. The CA noted that strict adherence to procedural rules might cause serious injustice. The Abadillas' motion for reconsideration was denied, leading to the present petition for review on certiorari.
Issue(s)
Whether the Court of Appeals erred in ruling that the Complaint for Recovery of Ownership, Annulment of Title with Damages (CV No. Q-97-31250) filed by Galarosa is not barred by the Orders dated September 16, 1993 and April 19, 1994 in the reconstitution case (LRC Case No. Q-3536[90]).
Ruling
The Court denies the petition and affirms the Decision and Resolution of the Court of Appeals, ordering the trial court to proceed with the trial of Civil Case No. Q-97-31250.
Ratio Decidendi
On the issue of whether the complaint is barred by prior judgment: The Court ruled that the principle of res judicata, specifically the "bar by prior judgment" aspect, requires identity of parties, subject matter, and causes of action. The Court found no identity of causes of action between the petition for reconstitution of title and the civil action for recovery of ownership and annulment of title with damages. A judicial reconstitution proceeding is primarily aimed at the restoration of a lost or destroyed instrument or the reissuance of a new duplicate certificate of title in its original form and condition. Its purpose is to have the title reproduced after proper proceedings, not to pass upon the ownership of the land covered by the lost or destroyed title. The certificate of title itself does not vest ownership but merely evinces title over a property, and registration under the Torrens System does not create or vest title as it is not a mode of acquiring ownership. Therefore, the issue of ownership, which is the principal subject of the civil action, was not touched upon in the reconstitution proceedings. The Court reiterated that any change in ownership must be the subject of a separate suit. The doctrine of "conclusiveness of judgment" was also found inapplicable because, while it does not require identity of causes of action, it requires identity of issues actually and directly resolved in a former suit. The genuineness of Galarosa's title, the subject of the reconstitution, is not determinative of the outcome of the civil case for recovery of ownership and annulment of title. The Court emphasized that the issue of ownership must be threshed out in a separate civil suit and should not be confused with reconstitution proceedings, citing Lee v. Republic of the Philippines and Heirs of De Guzman Tuazon v. Court of Appeals.
Main Doctrine
A petition for reconstitution of title is an action in rem aimed at the restoration of an instrument, not the determination of ownership, and therefore, a judgment in a reconstitution proceeding does not bar, under the principle of res judicata, a subsequent civil action for recovery of ownership and annulment of title, as there is no identity of causes of action.