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Res Judicata in Land Registration Cases

1) Spouses Valisno bought two parcels of land in 1964 and paid taxes on the property. In 1968, Cayaba ousted the Valisnos from the property, claiming he bought it in 1967. Cayaba built an apartment building on the land. 2) The Valisnos sued Cayaba in court for recovery of possession. The trial court ruled in their favor but the appellate court reversed the decision. 3) In 1979, Cayaba applied to register the title to the land. The Valisnos opposed this, but the trial court dismissed the opposition, finding the issue was already decided by the prior appellate court ruling. The Valisnos have appealed this decision.

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293 views1 page

Res Judicata in Land Registration Cases

1) Spouses Valisno bought two parcels of land in 1964 and paid taxes on the property. In 1968, Cayaba ousted the Valisnos from the property, claiming he bought it in 1967. Cayaba built an apartment building on the land. 2) The Valisnos sued Cayaba in court for recovery of possession. The trial court ruled in their favor but the appellate court reversed the decision. 3) In 1979, Cayaba applied to register the title to the land. The Valisnos opposed this, but the trial court dismissed the opposition, finding the issue was already decided by the prior appellate court ruling. The Valisnos have appealed this decision.

Uploaded by

Nico Balleber
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd

SPOUSES VALISNO VS. HON.

JUDGE PLAN and CAYABA


G.R. No. L-55152 August 19, 1986

FACTS:
On August 1964, spouses Valisno bought from one Agapita Blanco, two parcels
of land in Isabela. They proceeded to pay the taxes thereon. On August 1968, Cayaba
ousted the Valisnos on said property, claiming that he had bought the lands on June 30,
1967 from a certain Verano. Cayaba then erected a 6-story apartment on said property.
2 years later, Spouses Valisno instituted an action before Isabela CFI for recovery of
possession of said property. CFI ruled in favor of the spouses, but the CA reversed the
ruling and review having been denied before the SC, the CA decision attained finality.
On September 1979, Cayaba applied for registration of title over said parcel of
lands. Spouses Valisno filed their opposition, Cayaba then moved for the dismissal of
the opposition on the ground of res judicata or that the action is barred by prior
judgment. CFI granted the motion to dismiss the opposition to the application. Hence,
this petition for certiorari filed by petitioner Spouses.
ISSUE: W/N a res judicata applies in land registration cases
HELD:
YES. Although it is not common for a motion to dismiss on the ground of judicata
be filed in a land registration case, it does not mean that doing so is prohibited. Under
the Rules of Court, the rules may be applied to land registration cases in a suppletory
character or whenever practicable and convenient. For res judicata to be applicable, 1)
the former judgment must be final, 2) it must have been' rendered by a court having
jurisdiction of the subject matter and of the parties, 3) it must be a judgment on the
merits and 4) there must be between the first and second actions identity of parties, of
subject matter and of cause of action.
In this case, as between the first case decided by the CA, and the herein land
registration case, there is res judicata. The CA decision attained finality when the land
registration case was instituted, the CA had jurisdiction when it rendered its decision, it
was a decision based on the merits as it was made in consideration of position papers
submitted by both parties, and that between the two cases, there is an identity of
parties, of subject matter (which is the herein parcels of land) and the cause of action
( as the CA case and herein registration case both ultimately dealt with possession of
the parcels of land.

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