Parasac v. Republic
REITERATIONFacts
The Antecedents: Casiano Sandoval and Luz Marquez filed an application for registration of Lot No. 7453 in Isabela. A compromise agreement was later submitted, approved by the Court of First Instance (CFI), which adjudicated portions of the lot to various parties, including the Heirs of Clemencia Parasac and Liberato Bayaua. The National Land Titles and Deeds Registration Administration (NLTDRA) issued Decree No. N-198071 in favor of the Heirs of Clemencia Parasac and Liberato Bayaua, but the Registry of Deeds reported that the decree could not be found. Procedural History: The Heirs of Clemencia Parasac and Liberato Bayaua filed a petition for the issuance of a new decree. The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed this, arguing the original decision had not attained finality as the OSG was not furnished a copy. Two separate cases arose before the Court of Appeals (CA): CA-G.R. SP No. 54618, seeking annulment of the CFI's Decision dated March 3, 1981, and CA-G.R. CV No. 66594, an appeal from the Regional Trial Court's (RTC) order directing the issuance of a new decree. The CA's First Division, in CA-G.R. SP No. 54618, annulled the CFI's Decision, citing lack of jurisdiction and the failure to notify the OSG. The CA's Tenth Division, in CA-G.R. CV No. 66594, initially affirmed the RTC's order but later reversed itself upon motion for reconsideration by the Republic, recognizing the annulment of the underlying decision in CA-G.R. SP No. 54618. The Petition: The Heirs of Clemencia Parasac filed a Petition for Review on Certiorari before the Supreme Court, seeking to annul the CA's Resolution dated September 10, 2003, which reversed its earlier decision and declared the RTC's order null and void. They argued that the CA's First Division decision constituted a collateral attack on the CFI's decision, which they claimed had attained finality.
Issue(s)
Whether the Court of Appeals gravely erred in issuing the Resolution dated September 10, 2003, which granted the motion for reconsideration and reversed its earlier decision, thereby nullifying the RTC's order. Whether the decision of the Court of Appeals in CA-G.R. SP No. 54618, which annulled the CFI's decision, constituted a collateral attack on the CFI's decision that had allegedly attained finality. Whether the petition for the issuance of a new decree of registration was barred by res judicata.
Ruling
The Supreme Court denied the petition. It affirmed the Resolution of the Court of Appeals dated September 10, 2003, which granted the motion for reconsideration of the Republic of the Philippines, reversed its earlier decision, and declared the RTC's order null and void. The Court held that the annulment of the underlying decision by the CA's First Division rendered the decree void, and subsequent attempts to relitigate the matter were barred by res judicata.
Ratio Decidendi
On the annulment of the CFI's Decision and its effect on the decree: The Court affirmed the CA's ruling that the CFI's Decision dated March 3, 1981, approving the compromise agreement, was null and void. This was based on the principle that directors of the Bureau of Lands and Bureau of Forest Development lacked the authority to dispose of public domain lands without the participation of the Solicitor General, who is the mandated counsel of the Republic. The failure to furnish the OSG with a copy of the decision also meant it did not attain finality. Consequently, the issuance of Decree No. N-198071, which was based on this void decision, was also without legal basis. Therefore, the Heirs of Clemencia Parasac had no right to the issuance of the original decree, nor to a copy thereof. On the collateral attack and finality of judgment: The Court clarified that the petition before it arose from CA-G.R. CV No. 66594, concerning the issuance of a copy of the decree. The annulment of the CFI's decision in CA-G.R. SP No. 54618 was a separate but related proceeding. The decision in CA-G.R. SP No. 54618, which annulled the CFI's decision, had become final and executory after the petitioners' attempt to appeal it to the Supreme Court (G.R. No. 149446) was denied for failure to comply with procedural requirements. Thus, the CA's Tenth Division was bound by the First Division's decision, as the issue of the validity of the CFI's decision had already been definitively settled. On the applicability of res judicata: The Court held that the petition was barred by res judicata, specifically the conclusiveness of judgment. The issue of the validity of the CFI's Decision dated March 3, 1981, was directly litigated and decided in CA-G.R. SP No. 54618. Allowing the Heirs of Clemencia Parasac to pursue the issuance of a copy of the decree would amount to relitigating the very issue of the validity of the underlying decision, which had already been declared null and void and had become final. This would violate the principle that parties should not be permitted to litigate the same issues more than once, and would render the prior denial of their petition in G.R. No. 149446 nugatory.
Main Doctrine
A subsequent petition seeking the issuance of a copy of a decree of registration, which is based on a decision that has been annulled and set aside by a higher court, must be denied. The annulment of the underlying decision renders the decree void and incapable of registration. Furthermore, attempts to relitigate issues already decided in a final and executory judgment are barred by res judicata.