### Title:
**Rene Manuel R. Jose vs. Elizabeth Quesada-Jose, et al.**
### Facts:
**Key Parties:**
– **Petitioner:** Rene Manuel R. Jose
– **Respondents:** Elizabeth Quesada-Jose, Heirs of Luis Mario Jose (Nathaniel Sean P. Jose, Naomi Celena P. Jose-Chokr, Neill Emmanuel Q. Jose, Nicholas Matthew Q. Jose)
**Initial Dispute:**
– **1996:** Domingo Jose, father of the petitioner and respondents, faced a judgment as a solidary debtor to Trade Investment Development Corporation (TIDCORP).
– **Settlement:** Domingo asked Rene and Cynthia (Rene’s wife) to help settle the debt by ceding a portion of their 23-hectare Antipolo property.
**Property Transfer:**
– The 23-hectare property was subdivided and partly ceded to TIDCORP.
– Three new titles were issued:
– TCT No. R-19951 (109,234 sq. m. to TIDCORP)
– TCT No. R-19952 (104,081 sq. m. to Cynthia)
– TCT No. R-19953 (19,627 sq. m. to Cynthia)
**Payment Demand:**
– Rene demanded Domingo pay the fair value (P120 Million) of the property ceded to TIDCORP. Domingo executed a Deed of Revocation, asserting he and his wife were the original owners.
**Lawsuits:**
– **Collection Case (2005):** Filed by Rene and Cynthia against Domingo for the value of the ceded property. Upon Domingo’s death in 2005, his son Luis acted as substitute defendant.
– **Annulment Case (2008):** Luis filed for annulment of sale and cancellation of the titles before the RTC Antipolo.
### Procedural History:
1. **RTC of Manila (Collection Case):**
– **Judgment (2014):** Validity of the 1978 sale upheld; ordered payment to Rene and Cynthia.
– **Appeals:** CA and Supreme Court affirmed the decision; RTC Manila judgment became final and executory.
2. **RTC of Antipolo (Annulment Case):**
– **Motion to Dismiss (2015)** filed by Rene on grounds of litis pendentia.
– **RTC Ruling:** Dismissed the case on litis pendentia, citing same issues were already resolved in the collection case.
3. **Court of Appeals:**
– **Reversal (2018):** Found no litis pendentia, reinstated the annulment case, and remanded it for further proceedings.
### Issues:
1. **Whether the action for annulment of sale and cancellation of titles is barred by litis pendentia.**
2. **If the Court of Appeals erred in equating this case to an ejectment case where the issue of ownership may be provisionally ruled upon.**
### Court’s Decision:
**Supreme Court Ruling:**
– **Reversal of CA Decision:** The Court found litis pendentia applicable; the annulment case was barred.
– **Key Points:**
– **Identity of Parties:** Both cases involved Rene and Cynthia on one side and Luis (substituting Domingo and Emilia) on the other.
– **Identity of Causes of Action:** Both cases revolved around the ownership and validity of the sale of the Antipolo property based on the 1978 sale.
– **Compulsory Counterclaim:** Luis failed to file a compulsory counterclaim for annulment of title in the collection case, thus barring him from instituting a separate annulment action.
– **Forum Shopping:** Initiating multiple suits involving identical facts and parties against the same transaction, which was denied by the SC, is an act of forum shopping.
### Doctrine:
**Litis pendentia:** A doctrine applied to avoid multiplicity of suits, requiring the concurrence of:
1. Identity of parties.
2. Identity of rights asserted and reliefs prayed for.
3. Identity such that judgment in one would be res judicata in the other.
**Compulsory Counterclaims:** Failure to raise them in the original action precludes the filing of another suit on the same matter, to avoid forum shopping.
### Class Notes:
– **Elements of Litis Pendentia:**
1. Identity of parties.
2. Identity of rights claimed and reliefs sought founded on the same facts.
3. Action that would be res judicata in the other.
– **Compulsory Counterclaims:** Must be raised in the initial action; failure to do so bars subsequent related actions.
**Sec. 48 of the Property Registration Decree (PD 1529):**
– **Prohibition Against Collateral Attack:** Titles cannot be challenged indirectly in proceedings aiming for different reliefs.
### Historical Background:
This case exemplifies complexities in family disputes involving property ownership and the aftermath of actions like simulated sales. It underscores the importance of recognizing procedural doctrines such as litis pendentia to maintain judicial efficiency and avoid conflicting decisions. It highlights procedural rigor in ensuring titles issued under the Torrens system are secure against collateral attacks.
Leave a Reply