Lawyerly

GR No. 188395

2013-11-20

HEIRS OF LATE FELIX M. BUCTON v. SPS. GONZALO AND TRINIDAD GO

PEREZ, J.

As a general rule, every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefore and the law will no way oblige him to go beyond the certificate to determine the condition of the property.[38] However, this principle admits exceptions: x x x (a) person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of the certificate. One who falls within the exception can neither be denominated [as] innocent purchaser for value nor a purchaser in good faith; and hence does not merit the protection of the law.[39]

GR No. 195825

2013-02-27

SPS. ALFONSO v. LILIA V. DOMINGO

BERSAMIN, J.

The Philippines adopted the Torrens system through Act No. 496,[27] also known as the Land Registration Act, which was approved on November 6, 1902 and took effect on February 1, 1903. In this jurisdiction, therefore, "a person dealing in registered land has the right to rely on the Torrens certificate of title and to dispense with the need of inquiring further, except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry".[28]

GR No. 179543

2010-10-06

CAMPER REALTY CORP. v. MARIA NENA PAJO-REYES

CARPIO MORALES, J.

. . . a person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith; and hence does not merit the protection of the law.[11]

GR No. 178984

2009-08-19

ERLINDA MAPAGAY v. PEOPLE

CHICO-NAZARIO, J.

Once a judgment attains finality, it becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by this Court.[34] Decisions that have long become final and executory cannot be annulled by courts, and the appellate court is deprived of jurisdiction to alter the trial court's final judgment.[35] This doctrine is founded on considerations of public policy and sound practice that, at the risk of occasional errors, judgments must become final at some point in time.[36]

AM No. P-09-2644

2009-07-30

EDGARDO A. QUILO v. ROGELIO G. JUNDARINO

CHICO-NAZARIO, J.

The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matters and causes of action between the first and second actions.[12]

AM No. P-09-2644

2009-06-30

EDGARDO A. QUILO v. ROGELIO G. JUNDARINO

CHICO-NAZARIO, J.

The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matters and causes of action between the first and second actions.[12]

GR No. 143573

2009-01-30

ADORACION ROSALES RUFLOE v. LEONARDA BURGOS

LEONARDO-DE CASTRO, J.

We now determine whether respondents Burgos siblings and Leonarda Burgos were purchasers in good faith. It has been consistently ruled that a forged deed can legally be the root of a valid title when an innocent purchaser for value intervenes.[14]

GR NO. 166744

2006-11-02

AC ENTERPRISES v. FRABELLE PROPERTIES CORPORATION

CALLEJO, SR., J.

As gleaned from the Resolution, the dismissal was without prejudice. Since the PAB had no jurisdiction over the complaint and the dismissal was without prejudice, respondent's action before the RTC was not barred by res judicata or litis pendentia[70]. The decision of the PAB was not a decision on the merits of the case.[71] Consequently, the contention of petitioner that respondent is guilty of forum shopping has no factual basis.

GR NO. 129165

2006-10-30

SPS. RODRIGO COLOSO AND ELISA COLOSO v. SECRETARY ERNESTO V. GARILAO

VELASCO, JR., J.

While the Ravago Group were issued LTCs and subsequently, Emancipation Patents over the 26.5 hectares of land, these documents should be recalled and revoked as the said issuance contradicts the February 8, 1972 final Decision of the CAR. The Ravago Group cannot circumvent the valid effects of a final judgment of CAR Case No. 266-Bataan '69 by applying for LTCs from the Ministry of Agrarian Reform (now DAR). They are bound by the February 8, 1974 Decision under the principle of "conclusiveness of judgment." Said principle states that "a fact or question which was in issue in a former suit and there was judicially passed upon and determined by a court of competent jurisdiction, is conclusively settled by the judgment therein as far as the parties to that action and persons in privity with them are concerned and cannot be again litigated in any future action between such parties or their privies in the same court or any other court of concurrent jurisdiction on either the same or different cause of action, while the judgment remains unreversed by proper authority."[21]

GR NO. 160994

2006-07-27

WILFREDO v. PAULO FLORESCA

CALLEJO, SR., J.

x x x conclusiveness of judgment - states that a fact or question which was in issue in a former suit and there was judicially passed upon and determined by a court of competent jurisdiction, is conclusively settled by the judgment therein as far as the parties to that action and persons in privity with them are concerned and cannot be again litigated in any future action between such parties or their privies, in the same court or any other court of concurrent jurisdiction on either the same or different cause of action, while the judgment remains unreversed by proper authority. It has been held that in order that a judgment in one action can be conclusive as to a particular matter in another action between the same parties or their privies, it is essential that the issue be identical. If a particular point or question is in issue in the second action, and the judgment will depend on the determination of that particular point or question, a former judgment between the same parties or their privies will be final and conclusive in the second if that same point or question was in issue and adjudicated in the first suit. Identity of cause[s] of action is not required but merely identity of issues.[23] The question on the co-ownership of the subject property was already settled in the judgment based on compromise agreement in Civil Case No. 832-BG which categorically stated that the subject property, "consisting of a riceland, sandy land and swampland," is partitioned such that one-half of the said areas belongs to Victor, Juanito and Lilia while the other half belongs to Paulo.

GR NO. 163994

2005-12-16

EASTWORLD MOTOR INDUSTRIES CORPORATION v. SKUNAC CORPORATION

PANGANIBAN, J.

Settled is the rule that no valid transfer certificate of title (TCT) can issue from a void TCT, unless an innocent purchaser for value had intervened.[17] An innocent purchaser for value is one who buys the property of another, without notice that some other person has a right to or interest in the property, for which a full and fair price is paid by the buyer at the time of the purchase or before receipt of any notice of the claims or interest of some other person in the property.[18] The protection given to innocent purchasers for value is necessary to uphold a certificate of title's efficacy and conclusiveness, which the Torrens system ensures.[19]

GR NO. 122202

2005-05-26

HEIRS OF LATE FAUSTINA ADALID ALSO KNOWN AS CRISTINA ADALID NAMELY ELENA JAMITO v. CA

CHICO-NAZARIO, J.

The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matter and cause of action between the first and second actions.[18]

GR No. 135365

2004-08-31

ROSARIO BARBACINA v. CA

AUSTRIA-MARTINEZ, J.

It is necessary to determine whether all the elements for the application of the doctrine of res judicata are present in this case. In Cayana vs. Court of Appeals,[4] we enumerated such elements, to wit:For res judicata to apply, there must be (1) a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and, (3) identity of parties, subject matter and cause of action between the first and second actions.

	GR No. 188395 2013-11-20	HEIRS OF LATE FELIX M. BUCTON v. SPS. GONZALO AND TRINIDAD GO PEREZ, J.
As a general rule, every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefore and the law will no way oblige him to go beyond the certificate to determine the condition of the property.[38] However, this principle admits exceptions: x x x (a) person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or of sufficient facts to induce a reasonably prudent man to inquire into the status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of the certificate. One who falls within the exception can neither be denominated [as] innocent purchaser for value nor a purchaser in good faith; and hence does not merit the protection of the law.[39]
	GR No. 195825 2013-02-27	SPS. ALFONSO v. LILIA V. DOMINGO BERSAMIN, J.
The Philippines adopted the Torrens system through Act No. 496,[27] also known as the Land Registration Act, which was approved on November 6, 1902 and took effect on February 1, 1903. In this jurisdiction, therefore, "a person dealing in registered land has the right to rely on the Torrens certificate of title and to dispense with the need of inquiring further, except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry".[28]
	GR No. 179543 2010-10-06	CAMPER REALTY CORP. v. MARIA NENA PAJO-REYES CARPIO MORALES, J.
. . . a person dealing with registered land has a right to rely on the Torrens certificate of title and to dispense with the need of inquiring further except when the party has actual knowledge of facts and circumstances that would impel a reasonably cautious man to make such inquiry or when the purchaser has knowledge of a defect or the lack of title in his vendor or status of the title of the property in litigation. The presence of anything which excites or arouses suspicion should then prompt the vendee to look beyond the certificate and investigate the title of the vendor appearing on the face of said certificate. One who falls within the exception can neither be denominated an innocent purchaser for value nor a purchaser in good faith; and hence does not merit the protection of the law.[11]
	GR No. 178984 2009-08-19	ERLINDA MAPAGAY v. PEOPLE CHICO-NAZARIO, J.
Once a judgment attains finality, it becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by this Court.[34] Decisions that have long become final and executory cannot be annulled by courts, and the appellate court is deprived of jurisdiction to alter the trial court's final judgment.[35] This doctrine is founded on considerations of public policy and sound practice that, at the risk of occasional errors, judgments must become final at some point in time.[36]
	AM No. P-09-2644 2009-07-30	EDGARDO A. QUILO v. ROGELIO G. JUNDARINO CHICO-NAZARIO, J.
The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matters and causes of action between the first and second actions.[12]
	AM No. P-09-2644 2009-06-30	EDGARDO A. QUILO v. ROGELIO G. JUNDARINO CHICO-NAZARIO, J.
The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matters and causes of action between the first and second actions.[12]
	GR No. 143573 2009-01-30	ADORACION ROSALES RUFLOE v. LEONARDA BURGOS LEONARDO-DE CASTRO, J.
We now determine whether respondents Burgos siblings and Leonarda Burgos were purchasers in good faith. It has been consistently ruled that a forged deed can legally be the root of a valid title when an innocent purchaser for value intervenes.[14]
	GR NO. 166744 2006-11-02	AC ENTERPRISES v. FRABELLE PROPERTIES CORPORATION CALLEJO, SR., J.
As gleaned from the Resolution, the dismissal was without prejudice. Since the PAB had no jurisdiction over the complaint and the dismissal was without prejudice, respondent's action before the RTC was not barred by res judicata or litis pendentia[70]. The decision of the PAB was not a decision on the merits of the case.[71] Consequently, the contention of petitioner that respondent is guilty of forum shopping has no factual basis.
	GR NO. 129165 2006-10-30	SPS. RODRIGO COLOSO AND ELISA COLOSO v. SECRETARY ERNESTO V. GARILAO VELASCO, JR., J.
While the Ravago Group were issued LTCs and subsequently, Emancipation Patents over the 26.5 hectares of land, these documents should be recalled and revoked as the said issuance contradicts the February 8, 1972 final Decision of the CAR. The Ravago Group cannot circumvent the valid effects of a final judgment of CAR Case No. 266-Bataan '69 by applying for LTCs from the Ministry of Agrarian Reform (now DAR). They are bound by the February 8, 1974 Decision under the principle of "conclusiveness of judgment." Said principle states that "a fact or question which was in issue in a former suit and there was judicially passed upon and determined by a court of competent jurisdiction, is conclusively settled by the judgment therein as far as the parties to that action and persons in privity with them are concerned and cannot be again litigated in any future action between such parties or their privies in the same court or any other court of concurrent jurisdiction on either the same or different cause of action, while the judgment remains unreversed by proper authority."[21]
	GR NO. 160994 2006-07-27	WILFREDO v. PAULO FLORESCA CALLEJO, SR., J.
x x x conclusiveness of judgment - states that a fact or question which was in issue in a former suit and there was judicially passed upon and determined by a court of competent jurisdiction, is conclusively settled by the judgment therein as far as the parties to that action and persons in privity with them are concerned and cannot be again litigated in any future action between such parties or their privies, in the same court or any other court of concurrent jurisdiction on either the same or different cause of action, while the judgment remains unreversed by proper authority. It has been held that in order that a judgment in one action can be conclusive as to a particular matter in another action between the same parties or their privies, it is essential that the issue be identical. If a particular point or question is in issue in the second action, and the judgment will depend on the determination of that particular point or question, a former judgment between the same parties or their privies will be final and conclusive in the second if that same point or question was in issue and adjudicated in the first suit. Identity of cause[s] of action is not required but merely identity of issues.[23] The question on the co-ownership of the subject property was already settled in the judgment based on compromise agreement in Civil Case No. 832-BG which categorically stated that the subject property, "consisting of a riceland, sandy land and swampland," is partitioned such that one-half of the said areas belongs to Victor, Juanito and Lilia while the other half belongs to Paulo.
	GR NO. 163994 2005-12-16	EASTWORLD MOTOR INDUSTRIES CORPORATION v. SKUNAC CORPORATION PANGANIBAN, J.
Settled is the rule that no valid transfer certificate of title (TCT) can issue from a void TCT, unless an innocent purchaser for value had intervened.[17] An innocent purchaser for value is one who buys the property of another, without notice that some other person has a right to or interest in the property, for which a full and fair price is paid by the buyer at the time of the purchase or before receipt of any notice of the claims or interest of some other person in the property.[18] The protection given to innocent purchasers for value is necessary to uphold a certificate of title's efficacy and conclusiveness, which the Torrens system ensures.[19]
	GR NO. 122202 2005-05-26	HEIRS OF LATE FAUSTINA ADALID ALSO KNOWN AS CRISTINA ADALID NAMELY ELENA JAMITO v. CA CHICO-NAZARIO, J.
The requisites of res judicata are: (1) there must be a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and (3) there must be identity of parties, subject matter and cause of action between the first and second actions.[18]
	GR No. 135365 2004-08-31	ROSARIO BARBACINA v. CA AUSTRIA-MARTINEZ, J.
It is necessary to determine whether all the elements for the application of the doctrine of res judicata are present in this case. In Cayana vs. Court of Appeals,[4] we enumerated such elements, to wit:For res judicata to apply, there must be (1) a former final judgment rendered on the merits; (2) the court must have had jurisdiction over the subject matter and the parties; and, (3) identity of parties, subject matter and cause of action between the first and second actions.

RUFINA C. CAYANA v. CA