G.R. No. 202876
**Facts:**
1. **Original Land Ownership**: Petitioners, the heirs of Timbang Daromimbang Dimaampao (Timbang), represented by Cabib D. Alawi, claimed ownership of a 157,738 square meter parcel of land in Madaya, Marawi City, covered by OCT No. RP-355 and Homestead Patent No. 47201. The land was allegedly part of the dowry provided to Timbang by her husband, Cota Dimaampao (Cota), upon their marriage.
2. **Marriage and Divorce**: The marriage, governed by Muslim rites, led to a joint application for homesteading, and the land was consequently registered in both Cota and Timbang’s names. Later, Cota and Timbang divorced, and the latter continued to possess and own the land.
3. **Controversial Sale**: On April 10, 1978, Cota executed a deed of sale conveying the land to respondents Abdullah Alug, Hadji Bogabong Balt, and Heirs of Hadji Ali Pete Pangarungan, represented by Hadja Sittie Salima Pangarungan.
4. **Legal Action**: The petitioners filed a complaint with the Regional Trial Court (RTC) of Lanao del Sur, Marawi City on February 15, 2005, seeking to declare the deed of sale null and void, quiet title, and claim damages. They posited that Cota no longer owned the land post-divorce and the respondents were in bad faith as the petitioners were in possession of the land.
5. **Respondents’ Defenses**: Respondents denied the petitioners’ claims, asserting ownership since 1978 upheld by RTC Lanao del Sur, Branch 9, in a previous case (Civil Case No. 2410), which had attained finality. They argued the petitioners’ claims were unfounded, time-barred (prescription or estoppel), and contravened the rule on judicial stability.
6. **Procedural Posture**: The RTC initially denied the special and affirmative defenses. However, on appeal, the Court of Appeals (CA) granted the writ of certiorari, setting aside the RTC’s orders and dismissing the complaint. Consequently, petitioners sought review by the Supreme Court.
**Issues:**
1. **Whether the CA’s Decision was contrary to Law and Jurisprudence.**
2. **Whether an extension of time to file a motion for reconsideration is permissible.**
3. **Whether special and affirmative defenses should be resolved after trial on the merits.**
**Court’s Decision:**
1. **Finality of RTC’s Order**: The Court held that the RTC’s order was interlocutory, not final, permitting reconsideration. Therefore, it did not become final and executory, and a certiorari petition to the CA was appropriate. The CA was within its jurisdiction to review the RTC order.
2. **Res Judicata**: The Court affirmed the application of res judicata since there had been a final decision by RTC Lanao del Sur in Civil Case No. 2410, declaring Cota’s ownership and validity of the deed of sale. The heirs were in privity with their ancestors; thus, previously determined issues could not be relitigated.
3. **Prescription**: The Court found that the petitioner’s action was barred by prescription. The Deed of Sale executed in 1978 was registered, starting the prescriptive period. The action initiated in 2005 was beyond the ten-year period stipulated in Article 1144 of the Civil Code for actions upon a written contract.
**Doctrine:**
– **Res Judicata**: A final judgment by a competent court is conclusive upon the parties and their privies in subsequent suits involving identical issues.
– **Prescription of Actions**: Actions based on written contracts must be filed within ten years from the date the right of action accrues, in this case, from the registration date of the sale.
**Class Notes:**
– **Res Judicata Essentials**: Final judgment, jurisdiction over subject matter and parties, judgment on the merits, identity of parties, subject matter, and causes of action.
– **Interlocutory vs. Final Orders**: Interlocutory orders do not finally dispose of the case and can be modified anytime before final judgment.
– **Prescription under Civil Code Article 1144 (1)**: Actions upon a written contract must be filed within ten years from the date the action arises.
**Historical Background:**
The case illustrates the legal complexities in property disputes rooted in historical contexts of land rights, inheritance, and customary practices, highlighting the judicial system’s role in resolving issues of property ownership and the precedents that bind future generations to prior judicial determinations. The longstanding legal battles, such as those depicted, underscore the importance of timely legal recourse and the finality of court judgments in maintaining judicial stability and certainty in property rights.
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