**Facts:**
This case revolves around a dispute over a piece of agrarian land located in Meycauyan, Bulacan, Philippines. The Department of Agrarian Reform (DAR) initially awarded the land to Alejandro Berboso in 1981 under Presidential Decree No. 27, moving through various legal transfers and replacements of certificates until ending up titled under Alejandro’s heirs post his death in 1994. Victoria Cabral, the respondent, sought to cancel the emancipation patents (EP) related to this land, citing illegal sale transactions. Her first attempt was denied by both the agrarian reform adjudication boards and the courts, including the Supreme Court. However, she filed a second petition that led to the Provincial Agrarian Reform Adjudication Board (PARAB) ordering the cancellation of the EPs, a decision reversed by the DAR Adjudication Board (DARAB) but reinstated by the Court of Appeals (CA). This prompted Esperanza Berboso to file a petition before the Supreme Court.
**Issues:**
The Supreme Court addressed issues regarding:
1. The principle of res judicata and whether it applies to Cabral’s second petition.
2. Whether there was a violation of the prohibition against the sale of awarded agrarian reform land.
3. The legitimacy of targeting Certificates of Land Transfer through a petition for cancellation of EPs as an indirect or collateral challenge.
4. The application of the rules of evidence concerning unverified documents.
5. Forum shopping concerns raised by repeated litigation over the same dispute.
**Court’s Decision:**
1. The principle of *res judicata* did not apply because the causes of action for the first and second petitions were different — the second focused on allegations of an unauthorized sale.
2. Cabral failed to prove the alleged sale from Berboso to Fernando due to the reliance on an unauthenticated photocopy of the supposed agreement.
3. The petition for cancellation of EPs constituted a collateral attack on the certificates of title, which is prohibited under the law.
4. The Supreme Court found the CA’s decision to be erroneous for considering unauthenticated evidence and reversed it, reinstating the DARAB’s dismissal of Cabral’s petition.
**Doctrine:**
The case established or reiterated the doctrines related to the irrevocability of a certificate of title once it surpasses the one-year mark from issuance, the prohibition against collateral attacks on such titles, and the applicability of *res judicata* in the context of agrarian reform disputes.
**Class Notes:**
1. *Res judicata* applies when four elements concur: a final judgment, jurisdiction over the subject matter and parties by the rendering court, a judgment on the merits, and identity of parties, subject matter, and causes of action between the first and second actions.
2. Certificates of Title issued under the Torrens system become indefeasible one year after issuance, protecting landowners from subsequent claims that challenge the title’s validity indirectly.
3. A photocopy of a document is inadmissible as evidence without meeting specific conditions that justify the absence of the original document.
4. Forum shopping occurs when identical or substantially the same cases are filed in different courts, violating procedural rules and principles of judicial courtesy and efficiency.
**Historical Background:**
The case highlights the complexities of agrarian reform in the Philippines, established under various laws aimed at distributing land to tenant farmers. The landmark Presidential Decree No. 27 and the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657 are central to this effort, aiming to emancipate tenant farmers from the bondage of the soil and make them owners of the land they till. This case underscores the challenges in the implementation of agrarian reform policies, including issues related to the transferability of awarded lands and the finality and indefeasibility of land titles within the reform framework.
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