Moraga v. Somo
REITERATIONFacts
The Antecedents: The underlying dispute concerns a 1.7467-hectare agricultural land in Pandayan, Meycauayan, Bulacan. The land was originally owned by Victoriano Ipapo, who sold it to his daughters and their spouses (respondents) on March 7, 1973. Alejandro Moraga, the father of petitioner Enrique Moraga, was the tenant of this land. Alejandro Moraga executed an affidavit of consent to the sale on November 19, 1979, and a new title was issued to the respondents. However, unknown to the respondents, a Certificate of Land Transfer was issued to Alejandro Moraga on July 22, 1981, leading to the issuance of an Emancipation Patent and a new title in his name on September 16, 1993. The respondents filed a complaint for cancellation of these documents and for ejectment against the heirs of Alejandro Moraga, alleging irregularities in the issuance of the CLT, violation of retention rights, and breach of tenant obligations. Procedural History: The Provincial Adjudicator ruled in favor of the respondents, ordering the cancellation of the Emancipation Patent and ejectment of the Moragas. This decision was affirmed by the Court of Appeals in CA-G.R. SP No. 38445, which became final and executory. Separately, the respondents applied for retention of the land, which was granted by the DAR Regional Director and affirmed by the Secretary of Agrarian Reform, and subsequently by the Court of Appeals in CA-G.R. SP No. 38445. Meanwhile, the Moragas filed a complaint for redemption, alleging the sale was made without proper notice. The Provincial Adjudicator dismissed this complaint, finding it moot and prescribed. The DARAB affirmed the dismissal of the redemption claim but modified the decision to state that the heirs would remain tenants with security of tenure. Both parties appealed this DARAB decision. The Court of Appeals, in CA-G.R. SP No. 63895, affirmed the denial of the redemption claim. In CA-G.R. SP No. 70051, the Court of Appeals reversed the DARAB's ruling on security of tenure, finding it contradicted the final and executory decision in CA-G.R. SP No. 38445. The Petition: This Petition for Review under Rule 45 of the Rules of Court, filed by petitioner Enrique Moraga, seeks to nullify the Court of Appeals' decision in CA-G.R. SP No. 70051, which reversed the DARAB's order for the heirs to remain as tenants with security of tenure. The petitioner raises issues regarding his right of redemption, security of tenure, the respondents' right to eject him, and entitlement to disturbance compensation. The Supreme Court notes that the issues of redemption and security of tenure have already been settled by final and executory decisions in prior cases (CA-G.R. SP No. 63895 and CA-G.R. SP No. 38445, respectively), invoking the doctrine of res judicata. The Court also states that the claim for disturbance compensation is being raised for the first time and cannot be considered.
Issue(s)
Whether the petitioner has a right of redemption over the landholding. Whether the petitioner shall remain as a tenant of the landholding entitled to security of tenure, and whether the respondents have a legal right to eject the petitioner from the landholding. Whether the petitioner is entitled to disturbance compensation. Whether the decision in CA-G.R. SP No. 70051 nullified the decision in CA-G.R. SP No. 63895.
Ruling
The petition is denied. The Decision of the Court of Appeals dated 23 April 2004, and its Resolution dated 11 January 2005, in CA-G.R. SP No. 70051 are affirmed. Costs against the petitioner.
Ratio Decidendi
On the Right of Redemption: The Court held that the issue of redemption was already settled by the final and executory decision of the Court of Appeals in CA-G.R. SP No. 63895. This decision affirmed the DARAB's ruling that the petitioner's right to redeem the property had prescribed, as the complaint for redemption was filed beyond the 180-day period from notice of the sale. Furthermore, the Court noted that Alejandro Moraga's Sinumpaang Salaysay executed on November 19, 1979, was deemed a waiver of his right to redeem. Therefore, any attempt to relitigate this issue is barred by the doctrine of res judicata. On Security of Tenure and Ejectment: The Court found that the issue of security of tenure was definitively resolved in the final and executory decision of the Court of Appeals in CA-G.R. SP No. 38445. This decision ordered the ejectment of Alejandro Moraga and affirmed the DARAB's finding that he violated his obligations as a tenant, specifically by failing to pay rentals from 1990 and allowing third parties to occupy portions of the landholding without the landowners' consent. The Court clarified that any pronouncement in the body of the decision suggesting Moraga might remain a tenant was merely obiter dictum, as the dispositive portion clearly upheld his eviction. The subsequent ruling by the DARAB granting security of tenure was deemed an error, as it contradicted a final and executory judgment. On Disturbance Compensation: The Court ruled that the claim for disturbance compensation could not be considered because it was raised for the first time in the Petition for Review before the Supreme Court. The settled rule is that matters or issues not raised in the lower courts cannot be raised before the Supreme Court for the first time. Therefore, this claim was deemed waived. On the Alleged Nullification of Decisions: The Court clarified that the decision in CA-G.R. SP No. 70051 did not nullify the decision in CA-G.R. SP No. 63895. Instead, it corrected a palpable error by the DARAB and the Court of Appeals in CA-G.R. SP No. 63895, which had ventured into the issue of security of tenure despite it not being properly raised in the initial complaint for redemption. The Court emphasized that judgments must be confined to the issues presented by the parties, and rulings on unraised questions are irregular and invalid. Thus, the decision in CA-G.R. SP No. 63895 was valid only insofar as it denied the right to redeem, as the issue of security of tenure was improperly adjudicated therein.
Main Doctrine
The doctrine of res judicata bars the relitigation of issues that have been previously decided by a court of competent jurisdiction in a final and executory judgment. Matters not raised in the lower courts cannot be raised for the first time on appeal.