Ting v. Heirs of Lirio
REITERATIONFacts
The Antecedents: Spouses Diego Lirio and Flora Atienza applied for the registration of title to Lot No. 18281. Their application was granted by the Court of First Instance of Cebu in a decision dated December 10, 1976, which became final and executory on January 29, 1977. An order was issued directing the Land Registration Commission to issue the corresponding decree of registration and certificate of title. Procedural History: On February 12, 1997, Rolando Ting filed an application for registration of title to the same lot. The heirs of Diego Lirio opposed Ting's application, citing the prior decision in LRC No. N-983 and arguing that Ting's application was barred by res judicata. The Regional Trial Court (RTC) of Cebu dismissed Ting's application on the ground of res judicata. The Petition: Rolando Ting filed a petition for review on certiorari, raising the sole issue of whether the decision in LRC No. N-983 constituted res judicata in LRC No. 1437-N. Ting argued that since no decree of registration was issued and the decision was not revived within the ten-year prescriptive period, it had become "extinct" and could not be the basis for res judicata.
Issue(s)
Whether the decision in LRC No. N-983 constitutes res judicata in LRC No. 1437-N, considering the nature of land registration proceedings as in rem and the ministerial duty of the LRA. Whether the failure to issue a decree of registration and the lapse of the ten-year prescriptive period render the prior judgment in a land registration case unenforceable and incapable of forming the basis for res judicata, considering the distinction between ordinary civil actions and special proceedings like land registration cases.
Ruling
The petition is DENIED. The decision in LRC No. N-983 constitutes res judicata and bars the subsequent application of Rolando Ting for the registration of title to the same lot.
Ratio Decidendi
On the issue of res judicata and the enforceability of the prior judgment: The Supreme Court held that the decision in LRC No. N-983, which granted the application for registration of title to Lot No. 18281 in favor of the spouses Diego Lirio and Flora Atienza, became final and executory on January 29, 1977. Land registration proceedings are in rem, meaning they are directed against the whole world. Therefore, a final and executory judgment in such a proceeding settles the ownership of the land and is binding on everyone, including the petitioner Rolando Ting. The Court emphasized that the duty of the Land Registration Authority (LRA) officials to issue the decree of registration is ministerial and must conform to the court's decision; they act as officials of the court in this regard. On the applicability of the ten-year prescriptive period: The Court clarified that Section 6, Rule 39 of the Rules of Court, which provides for the enforcement of judgments by motion within five years and by independent action within ten years, applies only to ordinary civil actions and not to special proceedings like land registration cases. In Sta. Ana v. Menla, the Court explained that in special proceedings, the purpose is to establish a status, condition, or fact, such as ownership of land. Once ownership is proved and confirmed by judicial declaration, no further proceeding to enforce it is necessary, except in cases where the adverse party is in possession and the winning party seeks to oust them. The decision in a land registration case becomes final without further action upon the expiration of the period for appeal, unless the adverse party is in possession.
Main Doctrine
A final and executory decision in a land registration proceeding, which is an in rem action, constitutes res judicata and is binding on the whole world. The ten-year prescriptive period for enforcing judgments in ordinary civil actions under Section 6, Rule 39 of the Rules of Court does not apply to land registration cases.