G.R. No. 117247, April 12, 1996

Facts:

In August 1929, the Supreme Court ruled in Government of the Philippine Islands vs. Colegio de San Jose, declaring two parcels of land bordering Laguna de Bay as part of the Hacienda de San Pedro Tunasan owned by the Colegio de San Jose. In 1939, the Colegio sold these lots, along with an unregistered land, to the Government, which then subdivided the area into small lots for sale to bona fide occupants.

In December 1940, Lot 17, Block 78 of the Tunasan Homesite was sold to Apolonio Diaz, and in May 1948, Lot 19 was acquired by him, with his son Pastor Diaz appearing as the vendee. In January 1955, the heirs of Apolonio Diaz transferred their rights to both lots to Marta Ygonia, the mother of the petitioner, Manuel I. Ramirez. The Secretary of Agriculture and Natural Resources approved the transfer, and in July 1958, the Land Tenure Administration executed a deed of sale in favor of Marta Ygonia.

In May 1957, Marta Ygonia and her husband Arcadio Ramirez filed an application for land registration (LRC Case No. B-46) for a parcel of land claimed to be an accretion to Lot 17, measuring 11,055 square meters (later increased to 11,311 square meters). The application faced opposition from the Director of Lands, who argued that the applicants lacked sufficient title and that the land was part of the public domain. Canuto Ponce, a predecessor of the private respondent, also opposed the application, claiming the land was foreshore land covered by a revocable permit.

The trial court denied the application, concluding that the accretion existed prior to the acquisition of the Tunasan Homesite by the Government. The Court of Appeals affirmed this decision in 1968, which became final after the applicants failed to appeal.

Years later, on May 17, 1989, Manuel I. Ramirez filed a new application for registration of the same land formed by accretion (LRC Case No. B-526). The trial court ruled in favor of Ramirez, confirming his title to the land. However, Esmeraldo Ponce, the son of Canuto Ponce, later filed a special civil action for certiorari to annul the decree issued in favor of Ramirez, arguing that the earlier denial of registration constituted res judicata.

Legal Issues:

  1. Does the judgment in the earlier land registration case (LRC Case No. B-46) constitute res judicata, barring the subsequent application by the petitioner (Manuel I. Ramirez) for the same property?
  2. Did the Court of Appeals err in its interpretation and application of the doctrine of res judicata?

Arguments:

  • Petitioner (Manuel I. Ramirez):

    • Argued that res judicata did not apply because the basis for claiming registration in the two cases was different. In LRC Case No. B-46, the claim was based on possession from 1943, while in LRC Case No. B-526, the claim was based on possession starting in 1958 and continuing from 1988. Thus, the facts and circumstances surrounding each application were distinct.
    • Cited a previous ruling that indicated a judicial declaration of public land does not preclude subsequent applications for registration if the land remains alienable and disposable.

  • Respondent (Esmeraldo Ponce):

    • Contended that the earlier judgment in LRC Case No. B-46, which denied the application for registration, constituted res judicata. All elements of res judicata were present, including identity of parties, subject matter, and cause of action, despite the petitioner being a successor-in-interest.

Court's Decision and Legal Reasoning:

The Supreme Court ruled in favor of the petitioner, stating that the Court of Appeals erred in applying the doctrine of res judicata. The Court found that the basis for the claims in the two cases was indeed different, as the periods of possession cited were not the same. The Court emphasized that the right to relief in each case rested on different sets of facts, thus negating the identity of causes of action required for res judicata to apply.

The Court also noted that the previous ruling regarding public land did not bar the petitioner from seeking confirmation of title, provided the land remained alienable and disposable. The decision of the Court of Appeals was set aside, and the trial court's order granting registration in favor of the petitioner was affirmed.

Significant Legal Principles Established:

  1. Res Judicata: The elements of res judicata must be present, including identity of parties, subject matter, and cause of action. A change in the basis for claims can negate the application of res judicata.
  2. Land Registration: A judicial declaration that a parcel of land is public does not preclude subsequent applications for registration if the land remains alienable and disposable.