Imperial v. Pinigat
REITERATIONFacts
The Antecedents: The underlying dispute concerns a 248-square-meter residential lot with improvements. Rodrigo Imperial, Sr. claimed ownership based on a deed of sale from Isabelo Imperial in 1979. However, Isabelo allowed Juan Imperial and his wife Betty to reside in the house, and later, Juan and Betty's son-in-law and daughter, Rogelio and Asuncion Pinigat (respondents), also moved in. Betty alleged that Isabelo sold one-half of the property to Juan, and after Juan's death, she sold her portion to the respondents. This led to conflicting claims over ownership and possession of the property. Procedural History: Civil Case No. 627, a quieting of title case filed by Rodrigo Imperial, Sr., resulted in a Municipal Trial Court (MTC) decision recognizing the respondents' ownership of one-half of the property. This decision became final and executory. Subsequently, a survey revealed that portions of the houses of Spouses Rodrigo Jr. and Jocelyn Imperial, and Fe Imperial (petitioners) encroached upon the respondents' half. When the petitioners refused to vacate the encroached portions, the respondents filed an unlawful detainer case (Civil Case No. 845). The MTC ruled in favor of the respondents, ordering the petitioners to vacate. The Regional Trial Court (RTC) reversed the MTC's decision, finding a lack of jurisdiction and cause of action. The Court of Appeals (CA) then reversed the RTC, reinstating the MTC's decision. The Petition: The petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. They argued that the MTC's decision in Civil Case No. 627 did not apply to them as they were not parties to that case, and they questioned the validity of the relocation survey. The Supreme Court affirmed the CA's decision, holding that the final and executory judgment in Civil Case No. 627 was binding on the petitioners as successors-in-interest, and that the relocation survey was conducted properly in the presence of the parties.
Issue(s)
Whether the petitioners, as successors-in-interest and privies, are bound by the final and executory decision in Civil Case No. 627, even if they were not parties to the said case. Whether the relocation survey conducted to implement the decision in Civil Case No. 627 was valid and binding.
Ruling
The Supreme Court affirmed the Decision of the Court of Appeals, holding that the petitioners are bound by the final and executory decision in Civil Case No. 627, and that the relocation survey was validly conducted. The dispositive portion of the CA decision was affirmed.
Ratio Decidendi
On the binding effect of the prior judgment: The Court held that the petitioners, as successors-in-interest and privies to Rodrigo Sr. and his predecessors, are bound by the final and executory decision in Civil Case No. 627. The Court reiterated the principle that a judgment is binding not only on the parties but also on their successors-in-interest, citing Cabresos v. Tiro. The petitioners, by stepping into the shoes of their predecessors, cannot claim that the decision does not apply to them. The principle of nemo dat quod non habet (one cannot give what one does not have) was invoked, emphasizing that Rodrigo Jr. could only succeed to the portion of the estate that Isabelo owned at the time of his death, which was one-half, the other half having been validly sold to Juan. Fe Imperial, as the widow of Juan's son, had no basis for her claim of title directly from Isabelo. On the validity of the relocation survey: The Court found no merit in the petitioners' claim that the relocation survey was conducted unilaterally and without their participation. The records, particularly the affidavit of Sheriff Salvador Guevara, indicated that the geodetic engineer was appointed by the court and the survey was conducted in the presence of the parties, including the petitioners. The petitioners' failure to dispute the survey at the time it was conducted or in their subsequent pleadings before the RTC and CA led the Court to assume that it was conducted properly. The Court concluded that the petitioners were merely formulating issues to delay the execution of the final decision.
Main Doctrine
A final and executory decision of a court is binding not only on the parties thereto but also on their successors-in-interest and privies, who are deemed to have stepped into the shoes of the original litigants.