Selga v. Brar

G.R. No. 175151 (September 21, 2011)

Supreme Court dismissed Brar's property redemption attempt, citing res judicata on prior rulings.

Facts:

Francisco Entierro died intestate on March 7, 1979, leaving behind a parcel of land identified as Lot 1138-A in Himamaylan City, Negros Occidental, covered by Transfer Certificate of Title (TCT) No. T-10273. His spouse, Basilia Tabile, and their legitimate children executed a Deed of Sale with Declaration of Heirship on May 15, 1985, selling the property to petitioners Tobias Selga and Ceferina Garancho Selga for P120,000. This sale resulted in the cancellation of TCT No. T-10273 and the issuance of TCT No. T-134408 in the names of the petitioners.

On July 10, 1992, respondent Sony Entierro Brar, claiming to be a legitimate child of Francisco and Basilia, filed a Complaint for Annulment of Sale with Damages against the petitioners, alleging that she was preterited and deprived of her rightful share in the property. The Regional Trial Court (RTC) of Himamaylan City, Branch 55, ruled in her favor on May 8, 1996, declaring her as a legitimate heir and annulling the Deed of Sale, thus recognizing her right to a share of the property.

After the decision became final, respondent attempted to exercise her right to redeem the property on August 11, 1997, but the petitioners rejected her claim, arguing that her right to redemption had already been litigated. Consequently, on January 21, 1998, respondent filed a Complaint for Legal Redemption with Damages before RTC-Branch 56, which the petitioners countered with a defense of res judicata and forum shopping.

On July 27, 2001, RTC-Branch 56 dismissed the case, agreeing with the petitioners that the issue of legal redemption had already been resolved in the earlier case. Respondent appealed this decision to the Court of Appeals, which reversed the RTC's ruling on May 31, 2006, recognizing her right to redeem the property.

Legal Issues:

  1. Whether the right to redeem the property was barred by res judicata due to the final judgment in Civil Case No. 276.
  2. Whether the respondent had validly exercised her right to redeem the property.

Arguments:

  • Petitioners' Arguments:

    • The petitioners contended that the issue of legal redemption was already litigated in Civil Case No. 276, where the respondent's claims were dismissed. They argued that the finality of that decision barred any subsequent claims regarding redemption, as the elements of res judicata were satisfied: final judgment, jurisdiction, judgment on the merits, and identity of parties and causes of action.

  • Respondent's Arguments:

    • The respondent argued that her right to redeem the property was not explicitly ruled upon in Civil Case No. 276, and thus, the issue was not barred by res judicata. She maintained that her right to redeem was a statutory right that did not require judicial declaration to be enforceable.

Court's Decision and Legal Reasoning:

The Court of Appeals initially ruled in favor of the respondent, stating that her right to redeem the property was valid and that the previous case did not bar her claim. The appellate court emphasized that the right of legal redemption is inherent to co-heirs and does not need to be explicitly granted by the court. It noted that the absence of written notice regarding the sale to the respondent did not negate her right to redeem, as she had already asserted this right in her previous complaint.

However, upon review, the Supreme Court found merit in the petitioners' arguments. The Court held that the elements of res judicata were indeed present, as the final judgment in Civil Case No. 276 encompassed the same parties, subject matter, and cause of action. The Court clarified that the right to redeem was part of the issues that could have been raised in the earlier case, and the silence of the RTC on this matter indicated that it was not granted.

The Supreme Court reinstated the decision of RTC-Branch 56, concluding that the respondent's claim for legal redemption was barred by res judicata due to the finality of the earlier judgment.

Significant Legal Principles Established:

  1. Res Judicata: A final judgment rendered on the merits by a court of competent jurisdiction is conclusive of the rights of the parties in all other actions involving the same issues.
  2. Right of Redemption: The right of co-heirs to redeem property sold by their co-heirs is a statutory right that does not require explicit judicial declaration to be enforceable, but it must be asserted within the context of the legal proceedings.