Calalang v. Register of Deeds
REITERATIONFacts
The Antecedents: This case involves a dispute over the ownership and title of Lot 671, specifically a portion designated as Lot 671-A, located in Quezon City. The core of the controversy lies in conflicting claims stemming from a series of sales and registrations of the property. The original title for Lot 671 was issued to the Philippine Government. Subsequently, it was sold to Eugenia de la Paz and Dorotea de la Cruz, who then sold it to Lucia de la Cruz. Later, Eugenia de la Paz and Dorotea de la Cruz also sold portions of the lot to Amando Clemente and Narcisa de Leon. Lucia de la Cruz, in turn, sold portions of the property to the Iglesia Ni Kristo (INK). The petitioners in the consolidated cases claim ownership through titles derived from Amando Clemente and other buyers from him, whose titles date back to 1952. Procedural History: The underlying dispute over Lot 671 was previously adjudicated in Agustina de la Cruz et al. vs. Lucia de la Cruz, Iglesia ni Kristo and Hon. Court of Appeals (1984), where this Court affirmed the validity of Lucia de la Cruz's reconstituted title (TCT No. RT-58) and the subsequent sale to Iglesia ni Kristo, applying the principle of res judicata. The present petitions arise from motions for reconsideration filed by the petitioners in G.R. No. 76265 (Virginia Calalang) and G.R. No. 83280 (Augusto M. de Leon et al.) against the Court's decision dismissing their respective petitions. G.R. No. 76265 originated from a consulta filed by the Register of Deeds of Quezon City, while G.R. No. 83280 stemmed from an injunction suit dismissed by the Regional Trial Court. Both cases were elevated to the Supreme Court after adverse rulings in lower appellate courts or administrative bodies. The Petition: Petitioners, through separate motions for reconsideration, assail the Court's prior decision that dismissed their petitions. They argue that the doctrine of res judicata should not apply because they were not parties to the original de la Cruz case and that the facts presented in their cases differ significantly, particularly concerning the validity of the reconstitution proceedings and the chain of titles derived from Amando Clemente. Petitioners contend that their titles, issued in 1952, are indefeasible and that the reconstituted title of Lucia de la Cruz, and consequently the title of Iglesia ni Kristo, are void due to alleged procedural infirmities in the reconstitution process and the initial registration of the sale to Lucia de la Cruz. They seek a reconsideration of the dismissal, urging the Court to delve into the merits of their claims regarding ownership and the validity of the respective titles.
Issue(s)
Whether the principle of res judicata, specifically the conclusiveness of judgment, bars the relitigation of the ownership of Lot 671 and the validity of the reconstituted title of Lucia de la Cruz. Whether the petitioners, not being parties to the prior de la Cruz case, are bound by its judgment. Whether the reconstitution proceedings initiated by Lucia de la Cruz in 1971 were valid and conferred indefeasible title. Whether the registration of the sale to Lucia de la Cruz in the Register of Deeds of Manila in 1943 was the operative act conveying the property. Whether the titles derived from Amando Clemente are valid and superior to those derived from Lucia de la Cruz. Whether the petitions were procedurally correct, specifically regarding the proper remedy sought.
Ruling
The motions for reconsideration are DENIED. The Court affirmed its prior decision dismissing the consolidated petitions.
Ratio Decidendi
On the applicability of res judicata and conclusiveness of judgment: The Court held that the principle of res judicata, particularly the concept of conclusiveness of judgment, barred the relitigation of the ownership of Lot 671 and the validity of Lucia de la Cruz's reconstituted title. The issues raised in the present petitions were actually, directly, and expressly litigated and resolved in the 1984 de la Cruz case. The Court reiterated that when a right or fact has been judicially tried and determined by a competent court, it is conclusive upon the parties and those in privity with them. Even though the petitioners were not parties in the prior case, they were considered privies or successors-in-interest to the parties in the 1984 decision, as they derived their titles from the same predecessors-in-interest whose rights were adjudicated therein. The Court emphasized that identity of cause of action is not required for conclusiveness of judgment, only identity of issues. On the binding effect of the prior judgment on non-parties: The Court clarified that while the general rule is that a judgment binds only the parties, this rule has exceptions. Petitioners were bound by the 1984 decision because they were privies or successors-in-interest to the parties in that case. Their titles were derived from Amando Clemente, who in turn derived his title from Dorotea de la Cruz and Eugenia de la Paz, who were parties or whose rights were directly affected by the prior adjudication. The principle that parties ought not to be permitted to litigate the same issue more than once was invoked. On the validity of reconstitution proceedings: The Court reiterated that proceedings for judicial reconstitution of titles are in rem. Notice by proper publication, in accordance with law, is sufficient to clothe the court with jurisdiction. The mere fact that a person did not receive personal notice is not sufficient ground to invalidate the proceedings. The Court cited that publication in the Official Gazette vests the court with jurisdiction to hear and decide the petition. Therefore, the validity of the 1971 reconstitution proceedings was deemed settled by the prior decision. On the operative act of registration: The Court found no merit in the contention that the registration of the sale to Lucia de la Cruz in the Register of Deeds of Manila in 1943 was irregular. It was established that during the Japanese Occupation, transactions involving lands in Quezon City were recorded in Manila. The Court reiterated that the act of registration of the deed of conveyance is the operative act to convey land under the Torrens system, creating constructive notice to the whole world. The Court noted that the sale to Lucia was duly entered in the primary entry book. On the superiority of titles: The Court rejected the argument that titles issued in 1952 should prevail over INK's title. The titles claimed by petitioners were derived from TCT No. 5284, which was the reconstituted title of Dorotea de la Cruz. This title was declared null and void in the 1984 decision. Consequently, all subsequent titles derived from a void title are also void, applying the principle that the spring cannot rise higher than its source. On procedural correctness: The Court found that the petitions were procedurally erroneous. In G.R. No. 76265, the proper remedy from the Administrator's resolution was an appeal to the Court of Appeals, not a petition for certiorari and prohibition. In G.R. No. 83280, the petitioners failed to appeal the RTC's dismissal order and instead filed motions that were denied, making the order final and unreviewable by certiorari. The Court also noted that the petitions constituted a collateral attack on INK's title, which can only be challenged in a direct proceeding.
Main Doctrine
The principle of res judicata, specifically the concept of conclusiveness of judgment, bars the relitigation of issues that were actually, directly, and expressly raised, controverted, litigated, and resolved in a prior final and executory decision, even if the parties in the subsequent case were not impleaded in the prior case, provided they are privies or successors-in-interest. Furthermore, proceedings for judicial reconstitution of titles are in rem, and notice by publication is sufficient to confer jurisdiction, rendering the reconstituted title indefeasible and incontrovertible after one year from its issuance.